MEMORANDUM OF DECISION
JULIUS J. HOFFMAN, District Judge.
In this case the plaintiff seeks a refund of income taxes assessed against and paid by the plaintiff as trustee of certain trusts in the sum of $12,666.52 for the years 1962, 1963, and 1964.
Rosehill Cemetery Company (hereinafter referred to as "Rosehill") is an Illinois corporation with its principal place of business and principal office at
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