LEIBELL, District Judge.
The facts in this case have been stipulated in two stipulations of fact, copies of which are annexed to this opinion. Plaintiff seeks a refund of $19,910.04 on his 1944 income tax. The Government prays for a recoupment of $16,796.88, as a sum due on plaintiff's 1945 income tax.
The case at bar presents the question of the applicability of the equitable doctrine of recoupment in income tax cases. The doctrine was discussed and applied...
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