MEMORANDUM OPINION
FULTON, Chief Judge.
The Plaintiff, Washington Federal Savings and Loan Association of Miami Beach (hereinafter referred to as "Washington Federal"), instituted this action against the United States for a refund of income taxes in the amount of $100,446.91 for the year 1963. Washington Federal claims that said amount was collected from it erroneously in that the Commissioner failed to allow it to deduct, as an ordinary and necessary business...
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