POPE, Circuit Judge.
This was an action brought to recover a sum paid under protest as an assessed deficiency in income taxes. The deficiency was assessed against the plaintiff bank, appellant here, as transferee of the assets of the Wendell National Bank of Wendell, Idaho; that is to say, the taxable income here in question was that of Wendell National Bank.
Wendell National Bank had operated for many years when, on May 10, 1952, appellant bank purchased...
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