INGRAHAM, District Judge.
Memorandum:
This is an action to recover federal income taxes in the amount of $26,114.72, plus interest, which were allegedly erroneously assessed and collected from the plaintiff, Battelstein Investment Company, for the fiscal years ending January 31, 1962, and January 31, 1963. The taxes involved are those imposed by Sections 531 through 537 of the Internal Revenue Code of 1954, 26 U.S.C. Secs. 531-537.
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