MEMORANDUM OPINION
JOHNSON, Chief Judge.
Twitchco, Inc., a corporation, taxpayer in this case, seeks a refund of its income tax for the fiscal year ending May 31, 1967. The case is submitted upon the pleadings, motions, stipulated facts, and the briefs of the parties. Jurisdiction is based upon 28 U.S.C. § 1346(a) (1). As authorized by Rule 52 (a), Federal Rules of Civil Procedure, the appropriate findings of fact and conclusions of law will be incorporated...
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