MEMORANDUM OF DECISION
I. NATURE OF CONTROVERSY
ROBERT W. PORTER, District Judge.
Plaintiff, General Portland Cement Company (the name of which has been changed to General Portland, Inc.), complains that the United States (hereinafter referred to as the IRS or Service) erroneously assessed and collected $2,178,046.42 for the taxable years beginning December 31, 1960, through and including December 31, 1968.
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