OPINION
BELLONI, Chief Judge:
The Ralph W. Fullerton Insurance Agency brought this action for the recovery of $13,888.50, in federal income taxes plus interest alleged to have been overpaid by plaintiff for its 1969 and 1970 calendar years. Jurisdiction is based on 28 U.S.C. § 1346(a)(1).
Plaintiff is an incorporated general insurance agency located in Portland. Oregon. In August, 1968, plaintiff purchased all of the capital stock of James A...
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