MEMORANDUM AND ORDER ON CROSS-MOTIONS FOR SUMMARY JUDGMENT
WESLEY E. BROWN, District Judge.
This is a civil action for refund of $81,991.50 in income taxes plus interest paid for the year 1961. Plaintiff, the Southwest Grease and Oil Company, Inc., hereafter referred to as "Southwest Grease", or "taxpayer", claims that the overpayment resulted from the wrongful disallowance of certain items of expense incurred in connection with its redemption of convertible...
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