MEMORANDUM OPINION
DAUGHERTY, District Judge.
This action is for the recovery of income taxes collected on income earned by the investment of oil and gas royalties from restricted lands allotted to Jackson Barnett, a full-blood Creek Indian. The investments were made and the income therefrom was retained by the Superintendent of the Five Civilized Tribes. Income taxes are assessed and collected on this "reinvestment income," which taxes are the subject matter...
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