IGOE, District Judge.
Findings of Fact
1. The club duly filed a claim for refund, on December 31, 1946, on behalf of Albert Will, a member of the club who had paid during the tax period in question taxes in the total amount of $32 and whose power of attorney was attached to the claim. (Stip. Exs. A, B.) The claim for refund was disallowed November 2, 1948. (Stip. Ex. I.)
2. On October 31, 1949, 775 other members filed powers of attorney. Taxes collected...
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