Memorandum and Order
SINGLETON, District Judge.
This is a civil action brought by Tenneco, Inc. (Tenneco) against the United States of America (Government) for recovery of federal income taxes alleged to have been overpaid for the years 1959 and 1960. Jurisdiction has been stipulated and agreed to by the parties.
Tenneco brought this suit on behalf of itself and Midwestern Gas Transmission Company, a wholly owned subsidiary of Tenneco and...
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