NIELDS, District Judge.
This is a suit against the United States for the recovery of $19,798.94, alleged to have been erroneously or illegally collected from plaintiff as an additional income and excess profits tax for the year 1920. The additional tax arose from the disallowance by the Commissioner of Internal Revenue of an item of $48,070 deducted by the plaintiff from its 1920 tax return. The suit was tried by the court without a jury.
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