KOELSCH, Circuit Judge.
In this taxpayer's suit for the recovery of federal income and excess profits taxes for 1953 and 1954, paid pursuant to the deficiency determination by the District Director of Internal Revenue, both parties made motions for summary judgment. The District Court granted the Government's motion and the taxpayer has appealed.
Taxpayer is presently engaged in the structural pest control business in the San Francisco Bay Area; prior to 1953...
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