BREWSTER, District Judge.
In this proceeding the petitioner seeks to recover income taxes, assessed upon it as a business corporation, on its income for the years 1919, 1920, and 1921. The aggregate amount of the taxes paid was $2,159.07. The petitioner first returned this income as a trading, or business, corporation, but later filed amended returns, for the years involved, as a personal service corporation, and duly filed claims for refund, which were rejected....
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