WARLICK, District Judge.
This is an action for the refund of income taxes alleged to have been erroneously collected by the United States for the years 1945 and 1946. The amount directly involved in this action is $198,060.56, plus interest,— $87,658.47 being claimed for the year 1945 and $110,402.09 for the year 1946. The cause was heard on a series of stipulated facts and upon the oral testimony of two witnesses. The facts are generally undisputed.
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