FINDINGS OF FACT AND CONCLUSIONS OF LAW
MEHRTENS, District Judge.
This is a tax refund suit instituted by the plaintiff to recover taxes in the amount of $14,353.11 for the year 1961.
ISSUES
1. Whether defendant should be permitted to amend its answer to plead the affirmative defense of collateral estoppel.
2. Whether plaintiff is collaterally or directly estopped to deny that the amount of $33,308.15 paid to Aaron and Nancy Barzilay...
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