ST. SURE, District Judge.
This case was submitted to and decided before his death by the late Judge Kerrigan. The case has since been resubmitted to and considered by me. I have reached the same conclusion as did Judge Kerrigan, and I accordingly adopt his opinion, as follows:
"The dispute in this income tax case concerns the propriety of the application of credits for the overpayment of taxes for the years 1920 and 1921 to the unpaid balance of the 1918 tax...
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