ENGEL, Senior Circuit Judge.
The United States appeals from a judgment entered in the district court in favor of plaintiff Ohio National Life Insurance Company ("Ohio National"). The district court granted Ohio National the sum of $653,764.17 and statutory interest as presented in the stipulated amount of taxes which it had overpaid during the calendar years 1976, 1977 and 1978. The only question before the district court and on appeal is whether Ohio National's suit...
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