HAND, Circuit Judge.
This appeal is from a summary judgment dismissing the plaintiff's claim for a refund of part of its income taxes for 1943. The action was begun in 1953, based upon the disallowance by the Treasury of a credit asserted by the plaintiff for taxes paid to the Republic of Cuba for the year 1943. The facts were as follows.
The plaintiff, which was on an "accrual" basis as to its U. S. taxes, had issued several series of bonds, bearing interest...
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