WOOD, District Judge.
This is an action wherein the plaintiff seeks recovery of income taxes for the years 1951, 1952 and 1953. The defendant has filed an Amended Answer in which it asserts the right to offset or recoup certain underpaid taxes for the year 1953.
The plaintiff has moved to strike the defense of recoupment because the Government is barred by the statute of limitations from collecting the alleged underpaid taxes for the year 1953.
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