MEMORANDUM OPINION
DAUGHERTY, District Judge.
For many years, Taxpayer had followed the practice of capitalizing sales and use taxes it paid on equipment purchased by it as a part of the depreciable cost of the equipment. During the course of litigating a refund suit involving taxable years other than those in question here, it developed that this practice was erroneous because of the failure of the Taxpayer to file formal elections to capitalize such taxes...
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