MARTIN, District Judge.
In these consolidated civil actions, the petitioner, Commerce Title Guaranty Company, sues the United States of America for refund of capital stock taxes for the years ending June 30, 1936, and June 30, 1937, respectively; the payment of the taxes having been required by the Commissioner of Internal Revenue, pursuant to Sec. 105 of the Revenue Act of 1935, as amended by Sec. 401 of the Revenue Act of 1936, 26 U.S.C.A. Int.Rev.Acts.
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