PALMIERI, District Judge.
The plaintiff, a Delaware corporation, is engaged in the business of leasing and selling electric water, beer and frosted food coolers. It brings this action to recover alleged overpayments in income taxes for the years 1947 and 1948. The taxes were paid on profits realized from used coolers held for at least six months and sold to lessees while in their possession under standard rental agreements. The sole issue is whether these profits...
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