PAUL, Chief Judge.
The plaintiff sues for refund of alleged overpayments of income taxes for the fiscal years ended July 28, 1952, 1953, 1955, 1956, 1957 and 1958. The alleged overpayments resulted from the disallowance of deductions claimed for income permanently set aside for qualified charitable institutions, under 26 U.S.C. 1958 Ed. § 642.
The issues were submitted May 15, 1964, upon the respective motions of both parties for summary judgment, which...
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