METZGER, District Judge.
These two cases for the recovery of income taxes paid to the United States Internal Revenue Collector, were both tried in the same hearing.
The claim of American Factors, Limited was for recovery of taxes paid on sums deducted as exemptions from its 1932 gross income tax return, which exemptions were denied by the Collector, as follows:
(1) In 1924 the corporation, together with 23 of its stockholders, was sued by J. C. Isenberg...
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