CHESNUT, District Judge.
This is a federal income tax case. For the years 1945 and 1946 the Commissioner of Internal Revenue assessed a deficiency tax which was paid by the taxpayer, who petitioned for a refund which was overruled, and then brought this suit to recover the alleged overpayment. The facts are all stipulated and can be briefly stated.
The taxpayer is a Maryland corporation engaged in Baltimore City in the automobile service business including...
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