MEMORANDUM OPINION
LYNNE, Chief Judge.
These actions, consolidated for the purpose of this opinion, claim refunds of corporate income taxes paid for the calendar year 1967, together with interest as allowed by law. In case number 65-61, the taxpayer seeks a refund of $199,595.51; in case number 65-333, the taxpayer seeks a refund of $369,453.93. These cases were submitted upon stipulations of all material facts, and upon the briefs and oral arguments of...
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