OPINION
SWINFORD, Chief Judge.
This is an action for the recovery of income taxes in the sum of $104,935.66, plus a penalty of $33,065.42, plus interest in the amount of $26,233.92, for a total of $164,235, paid by the taxpayer for the year 1959. The record is before the court on the plaintiff's motion for summary judgment and on the defendant's motion for partial summary judgment.
The Webber Sausage Company, Inc. of Harrison County, Kentucky, is...
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