MEMORANDUM AND ORDER
WARREN, District Judge.
This case is a taxpayer's suit for refund of income taxes paid under protest in the amount of $412,840.47 plus interest for the fiscal year ended November 30, 1964.
The central question, involving one of the most complex parts of the Internal Revenue Code, is whether or not Koehring Overseas Corporation, S.A. ("KOS") was, during the year in question, a Controlled Foreign Corporation within the meaning...
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