OPINION
BARLOW, District Judge.
This is a suit for refund of income taxes, pursuant to 28 U.S.C. § 1346(a) (1).
On August 28th, 1968, the parties submitted this action to the court for determination upon a stipulation of facts which included the following in relevant part:
Chem-Atom Associates, of Princeton, New Jersey, Inc. (hereinafter Chem-Atom) was a holding company which owned, among other stock, eighty per cent (80%) of the stock...
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