KOSCINSKI, District Judge.
This is an action for refund of income taxes alleged to have been erroneously assessed and collected. Taxes for several years, beginning with the calendar year 1939, are involved. The complaint is framed in two counts, the first of which seeks recovery of the taxes as well as determination of allowability of tax deductions for carry-back and carry-over purposes; the second count is predicated upon an offer of settlement of these claims,...
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