LEMLEY, District Judge.
This cause is before the Court upon the motion for summary judgment filed herein by the defendants, Olin S. Godwin, District Director of Internal Revenue for the State of Arkansas, and John S. Lea, Acting District Director, and by the Intervenor, United States of America, which motion has been submitted upon the pleadings in the case and written briefs.
Union Planters National Bank, a national banking institution, brought this action...
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