DEVITT, Chief Judge.
This is an action for the recovery of $22,324.59, plus interest, which is alleged by the taxpayer, Fine Realty, Inc., to be an overpayment of its income tax for the taxable year 1955.
The taxpayer filed its federal income tax return for 1955 showing taxable net income of $10,369.22 and a tax liability of $3,110.77, which it paid. In 1959, the Commissioner of Internal Revenue recomputed taxpayer's net income — resulting in a tax...
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