MEMORANDUM
WANGELIN, District Judge.
This action was commenced by the plaintiff Elott Raffety Farms, Inc., against the defendant United States of America for the refund of income taxes paid in the taxable years ending March 31 of 1964, 1967, 1968, 1969 and 1970. Plaintiff claims deductions totalling $222,000.00 "advanced" by it to a farming enterprise in the Republic of Mexico. The enterprise succumbed to adverse weather and other growing conditions in 1966...
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