LITTLETON, Judge.
The plaintiff seeks to recover documentary stamp taxes in the amount of $110,321.20 alleged to have been erroneously collected from plaintiff on the issuance by it of approximately $100,290,000 worth of "income debenture certificates." These instruments were issued by plaintiff, a wholly owned subsidiary of the Metropolitan Life Insurance Company, to its parent corporation to evidence sums of money advanced by Metropolitan to plaintiff. The question...
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