LARAMORE, Judge.
This is a suit to recover income taxes paid by the plaintiff for the years 1951 through 1953 in the amount of $472,607.22, plus interest, on the theory that the taxpayer qualifies as a "western hemisphere trade corporation."
The sole issue in this case is whether the taxpayer is entitled to the special credit under section 26(i) of the Internal Revenue Code of 1939. Revenue Act of 1950, ch. 994, 64 Stat. 906, 920, as amended, 26 U.S.C. §...
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