RICE, District Judge.
From the pleadings of the parties, the stipulations filed herein, and the evidence introduced at the trial of the above cause on July 12, 1954, and in accordance with Rule 52(a) of the Federal Rules of Civil Procedure, 28 U.S.C.A., this Court makes and enters the following Findings of Fact and Conclusions of Law:
1
This is an action of a civil nature, arising under the laws of the United States, particularly the Revenue Acts...
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