FOLEY, District Judge.
The case was submitted on a Stipulation of Facts. Therefore, the Court makes its findings of fact in accordance therewith as follows:
Findings of Fact
1. This action is brought against the defendant by virtue of the provisions of Section 41 (20) of Title 28 United States Code [now 28 U.S.C.A. § 1346], and arises under the Internal Revenue laws of the United States and particularly Section 3475(a) of the Internal Revenue...
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