EDELSTEIN, District Judge.
The case arises on cross motions for summary judgment, no issues of fact being presented. Plaintiff sues to recover $461.45, assessed in connection with an alleged sale of real property, for federal documentary stamp taxes under § 3482 of the Internal Revenue Code, and paid under protest. The plaintiff liquidated five of its wholly owned subsidiaries, each of whom possessed assets in excess of liabilities. In each transaction, the subsidiary...
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