CUMMINGS, Circuit Judge.
These appeals are from two judgments in favor of the United States in refund suits brought by plaintiff. In both cases, much smaller refunds were allowed than sought by plaintiff, thus causing it to appeal. The only question for us is whether the district judge correctly held that the Commissioner of Internal Revenue did not abuse his discretion under Section 446(b) of the Internal Revenue Code of 1954 by requiring taxpayer's subsidiary, Shopper...
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