KENNERLY, District Judge.
This is a suit by plaintiff, The First National Bank of Houston, Houston, Texas (for brevity called Taxpayer), and its successor, First National Bank in Houston (for brevity called Successor Taxpayer), against defendant, Collector of Internal Revenue (for brevity called Collector), to recover $21,316.49, plus $3,118.92 interest, claimed by plaintiffs to have been unlawfully and under protest paid September 14, 1940, to Collector as income...
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