GARDNER, Circuit Judge.
Appellant brought this suit to recover $55,031.01 from appellee in his capacity as Collector of Internal Revenue, which amount it was alleged had been exacted from appellant for taxes for the years 1932 and 1933 under Section 104 of the 1932 Revenue Act, 26 U.S.C.A. Int.Rev. Acts, page 508. The lower court made findings of fact and entered conclusions of law sustaining the assessments as made and collected, and entered judgment dismissing appellant...
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