NORDBYE, Chief Judge.
This proceeding is an action seeking a refund of income taxes and interest paid to the Government in the sum of $33,446.67. The record consists of a stipulation of facts and the testimony of plaintiff. The taxes in question were paid pursuant to the assessment of the District Director of Internal Revenue with respect to certain transactions which took place in the year 1947 and which the Director claimed constituted a dividend to plaintiff and...
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