SANBORN, Circuit Judge.
This is an appeal by the United States from a judgment for a taxpayer (appellee) in an action for the refund of corporate income tax deficiencies alleged to have been erroneously assessed and collected for the calendar years 1956, 1957 and 1958. The action was brought after timely claims for refund had been denied. The deficiency in each of the years was based upon the disallowance by the Commissioner of Internal Revenue of the major portion...
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