MEMORANDUM
INGRAHAM, District Judge.
This is a suit wherein the plaintiff, Bar L Ranch, Inc., seeks refund of a delinquency penalty in the amount of $403.12. The penalty was incurred by the plaintiff for late filing of its fiscal 1962 income tax return. The United States has intervened in the suit and seeks to collect an additional $25,515.37 of alleged taxes, penalties and interest due from the plaintiff for fiscal 1962.
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