OPINION
SEAR, District Judge:
Plaintiff, Empire Land Corporation, a Louisiana corporation with its principal place of business in New Orleans, Louisiana, is the successor by merger to Universal Drilling Corporation (Universal), a Delaware corporation which had its principal place of business in New Orleans. Empire sued the United States for a refund of $87,283.57 in corporate income taxes for fiscal 1965 which it alleges were improperly assessed against...
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