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LIBERTY LOAN CORPORATION v. UNITED STATES

No. 73-1389.

498 F.2d 225 (1974)

LIBERTY LOAN CORPORATION, Appellee, v. UNITED STATES of America, Appellant.

United States Court of Appeals, Eighth Circuit.

Decided May 31, 1974.

Rehearing Denied July 19, 1974.

Attorney(s) appearing for the Case

John A. Townsend, Atty., Tax Div., Dept. of Justice, Washington, D. C., for appellant.

William D. Crampton, St. Louis, Mo., for appellee.

Before VAN OOSTERHOUT, Senior Circuit Judge, and LAY and HEANEY, Circuit Judges.

Rehearing En Banc Denied July 19, 1974.

LAY, Circuit Judge.

The United States appeals from a judgment of the district court granting Liberty Loan Corporation (hereinafter taxpayer) a refund of $246,292.28 plus interest for 1961 income taxes alleged to have been wrongfully assessed and paid. The trial court's opinion is reported at 359 F.Supp. 158 (E.D.Mo.1973). We reverse the judgment for the taxpayer and remand with directions...

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