MEMORANDUM OF DECISION
SWEIGERT, District Judge.
This is an action brought by Transamerica Corporation (hereinafter referred to as Transamerica) pursuant to the provisions of 68A Stat. 876 (1954), 26 U.S.C. Sec. 7422 (1964) and 62 Stat. 933 (1948), 28 U.S.C. Sec. 1346(a) (1) (1964) for a refund of federal income taxes for the calendar year 1958.
Jurisdiction is invoked under the provisions of 28 U.S.C. Secs. 2401-2402 (1964).
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