KERRIGAN, District Judge.
This is an action to recover $13,426, paid under protest to cover a deficiency in income tax assessed against plaintiff for 1919, and $1,154.31 similarly paid for 1920. Plaintiff was, and had been for many years, a wine and brandy broker, doing business under the name of "Landsberger & Son." His dealings were with wholesalers only, with whom he negotiated for the purchase of whole cellars. This business was in flourishing condition prior...
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