MEMORANDUM
FRANK GRAY, Jr., District Judge.
This action was brought by Starday Recording and Publishing Company, Inc. (hereinafter referred to as Starday) to recover excise taxes paid by it subsequent to an assessment by the Commissioner of Internal Revenue. The Commissioner determined that the selling price shown on plaintiff's books in connection with transactions with Starday International Sales, Inc. (hereinafter referred to as International) and the...
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