WHALEY, Judge.
The plaintiff brings this suit for interest on alleged overpayments of income taxes for the year 1918 and 1919 which it claims were refunded to it. The controversy arises in the following manner:
Prior to and during 1927, the Commissioner of Internal Revenue had under consideration the returns of the plaintiff for the years 1918, 1919, and 1920, and, as a result of his audits, he determined an overassessment for 1918 of $80,072.44, an overassessment...
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