ORDER
TIDWELL, District Judge.
The above-styled suit for refund of federal income taxes previously paid by the plaintiff is presently before the court on the parties' cross-motions for summary judgment. The following facts have been stipulated by the parties:
1. The plaintiff, Presto Products, Incorporated, is a wholly-owned subsidiary of The Coca-Cola Company, whose principal place of business is 310 North Avenue, Atlanta, Fulton County, Georgia...
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