MEMORANDUM OPINION
WEBSTER, District Judge.
In this tax refund suit, plaintiff Liberty Loan Corporation seeks recovery of amounts paid as an assessed deficiency resulting from the "reallocation" by the Commissioner of Internal Revenue of taxable income between plaintiff and some, but not all, of its subsidiaries. See 26 U.S.C. § 482.
The jurisdictional facts are not in dispute. Plaintiff timely filed its 1961 corporate federal income tax return...
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