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TITLE GUARANTEE COMPANY v. UNITED STATES

No. 120-69.

432 F.2d 1363 (1970)

The TITLE GUARANTEE COMPANY v. The UNITED STATES.

United States Court of Claims.

October 16, 1970.

Attorney(s) appearing for the Case

Lydia E. Kess, New York City, for plaintiff. Wallace S. Jones, New York City, attorney of record.

Michael H. Singer, Washington, D. C., with whom was Asst. Atty. Gen. Johnnie M. Walters, for defendant. Philip R. Miller and Joseph Kovner, Washington, D. C., of counsel.

Before COWEN, Chief Judge, and LARAMORE, DURFEE, DAVIS, COLLINS, SKELTON, and NICHOLS, Judges.

OPINION

SKELTON, Judge:

This is a suit for refund of income taxes in the sum of $42,218.01 and interest paid thereon in the sum of $12,672.80, all in the total sum of $54,890.81, plus any additional interest and amounts as may be legally refundable for the calendar years 1960 through 1964. The facts giving rise to this controversy are fully set forth in the following portions of the stipulation of facts agreed to by the parties and filed herein:

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