MEMORANDUM AND ORDER
REGAN, District Judge.
In this action for refund of income taxes allegedly overpaid for the year 1970 both parties have moved for summary judgment. Involved is the application and construction of Section 7422 (e), 26 U.S.C.
The relatively few facts are not in dispute. Plaintiff timely filed its corporate income tax return for the calendar year 1970, reporting (and paying) an accumulated earnings tax in the sum of $19,000. Thereafter...
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