MEMORANDUM AND ORDER
STEPHENSON, Chief Judge.
This is an action for the refund of income taxes and interest with respect to an alleged overpayment of Federal Income Taxes for the taxable years ending December 31, 1962 and 1963. The jurisdiction of the Court pursuant to 28 U.S.C. § 1346(a) (1) is established. All facts have been stipulated and are found accordingly.
The plaintiff is a banking corporation authorized to operate within the State...
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