ON PLAINTIFF'S MOTION FOR PARTIAL SUMMARY JUDGMENT AND DEFENDANT'S CROSS MOTION FOR PARTIAL SUMMARY JUDGMENT
KASHIWA, Judge:
This is an action for the recovery of an alleged overpayment by plaintiff of federal corporate income taxes in the amounts of $61,750.70, $173,151.11 and $366,743.41 for its fiscal years 1966, 1968 and 1969 respectively, plus assessed and statutory interest thereon. These amounts were paid as a result of a determination by the Commissioner...
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