LITTLETON, Judge.
The plaintiff, herein sometimes referred to as "Transamerica," seeks to recover an alleged overpayment of income tax of approximately $60,000, on account of an additional assessment in 1940 for the year 1936, the exact overpayment to be stipulated by the parties, on the basis of the decision of the court if plaintiff is held entitled to recover on the issue presented as to the deductibility of certain amounts totalling $805,376.76, as ordinary and...
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