GODDARD, District Judge.
The plaintiff, the United States of America, sues to recover from the defendant, Niagara Hudson Power Corporation (hereinafter referred to as Niagara Hudson) $4,915.50 alleged to be due as documentary stamp taxes in connection with the merger or consolidation of Northern Development Corporation (hereinafter referred to as Northern) and Oswego Corporation (hereinafter referred to as Oswego), two of the defendant's wholly-owned subsidiaries...
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