OPINION
BONSAL, District Judge.
This is an action for a refund of $168,338.53 in Federal income taxes paid by the plaintiff, Educational Fund of the Electrical Industry (Educational Fund) for the years 1958 through 1961. The court has jurisdiction under 28 U.S.C. § 1346.
The action was tried before the court without a jury and the parties thereafter submitted proposed findings of fact and conclusions of law.
Pursuant to Rule 52(a), F...
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