OPINION
ROBERT L. CARTER, District Judge.
Plaintiff ("ATT") and defendant both move pursuant to Rule 56(a), F.R.Civ.P., for summary judgment. They have submitted a joint 9(g) statement, and there are no material issues of fact to be resolved.
Facts1
When ATT filed its 1964 federal income tax return, it claimed a foreign tax credit of $269,085.10 based on its...
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