MAJOR, Circuit Judge.
This is an appeal from a decision of the District Court denying appellant's claim for refund in the amount of $10,095.38, with certain interest thereon, asserted to have been illegally collected for the year 1920. The controversy involves a construction of section 234 of the Revenue Act of 1918 (40 Stat. 1077) as follows:
"Sec. 234. (a) That in computing the net income of a corporation subject to the tax imposed by section 230 there shall...
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