OTIS, District Judge.
This is an action to recover alleged excess taxes in the sum of $18,755.86, paid for the year 1918. Recovery of this amount is sought under and by virtue of the provisions of section 234(a) (14) of the Revenue Act of 1918 (40 Stat. 1079), which, so far as is here pertinent, reads as follows:
"At the time of filing return for the taxable year 1918 a taxpayer may file a claim in abatement based on the fact that he has sustained a substantial...
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