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COMMUNITY LOAN & INVESTMENT CORP. (GA.) v. UNITED STATES

Civ. A. No. 8800.

241 F.Supp. 434 (1965)

COMMUNITY LOAN & INVESTMENT CORPORATION (GEORGIA), Plaintiff v. UNITED STATES of America, Defendant.

United States District Court N. D. Georgia, Atlanta Division.

March 23, 1965.

Attorney(s) appearing for the Case

Allen Post, Atlanta, Ga., and George G. Tyler and Richard J. Hiegel, New York City, for plaintiff.

Charles Goodson, U. S. Atty., Atlanta, Ga., for defendant.

HOOPER, Chief Judge.

The plaintiff, doing business in Georgia as a small loan company, brought this action seeking to recover an alleged overpayment of income taxes. All of the material facts in the case are stipulated by the parties. The sole question is whether or not under the facts in the record certain certificates issued by the plaintiff to parties borrowing money from the plaintiff shall be considered as borrowed

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