ELY, Circuit Judge:
This appeal is from a District Court decision in favor of the Government in an action for tax refund instituted by taxpayer under 28 U.S.C. § 1346(a) (1) (1964). Taxpayer properly invokes our jurisdiction under 28 U.S.C. § 1291 (1964).
The taxpayer, a company engaged in the manufacture and sale of both multiwall and textile bags, sold its multiwall bag business to West Virginia Pulp and Paper Company. Negotiations, initiated by...
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