WILBUR, Circuit Judge.
This action was brought by the appellant to recover income tax paid to the appellee for the taxable years 1918 to 1921, inclusive. The appellant was engaged in the furniture business from and after 1912. A considerable part of its sales were made on the installment basis. It reported its income from such sales upon the accrual basis for the taxable years 1913 to 1917, inclusive. In 1919 it elected to file its return on the installment basis...
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