ANDERSON, Chief Judge.
The plaintiff, a Rhode Island corporation, seeks in this action to recover certain alleged overpayments of federal income taxes made by two predecessor corporations for the fiscal years ending June 30, 1949, June 30, 1950 and December 17, 1948. The motion is, in effect, one for partial summary judgment, since it seeks to have decided the last two counts and only a portion of the first count of the three-count complaint. However, the only question...
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