ST. SURE, District Judge.
Plaintiff sues to recover documentary stamp tax in the amount of $16,514.12, paid under protest on June 14, 1941. The tax was assessed by the Collector of Internal Revenue under the provisions of §§ 1800, 1802, Internal Revenue Code, 26 U.S.C.A.; Schedule A-3 of Treasury Regulation 71, on the transfer of stock in connection with the merger of The Emporium Capwell Company (a California corporation), the plaintiff, and The Emporium...
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