Memorandum Opinion
HENLEY, Chief Judge.
This is a suit brought against the United States by Newport Federal Savings & Loan Association for the purpose of securing a refund of income tax, negligence penalty and interest, paid by it following a deficiency assessment made by the Commissioner of Internal Revenue with respect to calendar year 1960. The cause is now before the Court on the cross motions of the parties for summary judgment.
Plaintiff...
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