LITTLETON, Judge.
The controlling facts in this case are simple, but a detailed explanation of all that occurred between the Commissioner of Internal Revenue and the Blue Jay Lumber Company is somewhat confusing by reason of the fact that the Commissioner in June, 1923, erroneously assessed the tax due and paid by Blue Jay in the name of a subsidiary corporation known as the Del Rio Lumber Company, which had no taxable income and paid no tax for 1922.
The...
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