VAUGHT, District Judge.
This is an action to recover $2,469.50, plus interest, paid under protest to the District Director of Internal Revenue at Nashville, Tennessee, on March 26, 1956, for which a claim for refund was disallowed on July 2, 1957.
The case was submitted to the court upon the agreed stipulation of facts and briefs. The facts as stipulated are as follows:
"1. Price Motors, Inc., plaintiff herein, was incorporated on November 2, 1953...
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