TEHAN, District Judge.
Plaintiff taxpayer, a Wisconsin corporation, brings this action for refund of undistributed profits surtax paid for the year 1936 in the sum of $23,672.61, with interest thereon from the date of payment. The taxes were paid under the Revenue Act of 1936, 49 Stat. 1648, § 14, 26 U.S.C.A.Int.Rev.Acts, page 823, which imposed a surtax on corporate net income earned during the tax year but not distributed as dividends.
In 1942, the...
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