REGAN, District Judge.
This is an action instituted under Title 28 U.S.C. § 1346 by the taxpayer, United Development Company, for a refund of $22,594.63 plus interest.
The basic facts are not in dispute. Plaintiff is a Missouri corporation which owns and operates a cemetery in St. Louis County, Missouri, which, prior to July 5, 1956, consisted of approximately 64.16 acres of real property. On July 5, 1956, plaintiff sold approximately 19 acres of the...
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