McDERMOTT, Circuit Judge.
Appellant filed its petition to recover $2,482.59 income taxes paid under protest for the 1931 tax year, and for $3,287.88 similarly paid for the 1932 tax year. The trial court sustained a demurrer to the petition; appellant elected to stand and judgment went against it.
The controversy grows out of a transaction by which appellant acted as trustee to realize upon the assets of a...
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