OPINION and JUDGMENT
DALTON, Chief Judge.
The Broadway Theatre League of Lynchburg, Virginia, Inc., hereinafter referred to as the League, brings this action pursuant to the provisions of 28 U.S.C.A. § 1346(a) (1), seeking to recover income taxes including interest and penalties imposed, alleged to have been erroneously and illegally assessed and collected by the Internal Revenue Service for the fiscal years ending April 30, 1963, and April 30, 1964...
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