RAYMOND, District Judge.
Plaintiff in this suit sues to recover alleged overpayments made by it on income and excess profits taxes for the years 1918 and 1919. The controversy arises out of the application and construction of sections 202 (a) (1) and 234 (a) (9) of the Revenue Act of 1918 (40 Stat. 1060, 1077), and regulations prescribed by the Commissioner of Internal Revenue
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