MEMORANDUM DECISION
NORDBYE, Senior District Judge.
In this proceeding, plaintiff, a Minnesota corporation, seeks to recover certain federal income taxes disallowed by the Internal Revenue Service which were paid for the fiscal years ending July 31, 1962, 1963 and 1964, in the amount of $2,450 for each of these fiscal years as the annual amortization of the cost of the acquisition of a ten-year management contract with the Union Mutual Insurance Company...
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