OPINION
SUGARMAN, Chief Judge.
This action involves the income tax assessments to be made by the Government of India against A. K. Jain for the assessment years 1957-58 through 1960-61. Mr. Jain was Managing Director of a Liechtenstein corporation during those years that was very active in international finance.
Two of the institutions he and the corporation did business with are Brown Brothers, Harriman & Co. and The Chase Manhattan Bank. The...
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