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HOME SAVINGS AND LOAN ASS'N v. UNITED STATES

No. 73-2690.

514 F.2d 1199 (1975)

HOME SAVINGS AND LOAN ASSOCIATION, Plaintiff-Appellee, v. UNITED STATES of America, Defendant-Appellant.

United States Court of Appeals, Ninth Circuit.

As Amended on Denial of Rehearing June 16, 1975.

Attorney(s) appearing for the Case

Ernest J. Brown, Atty., Tax Div., Dept. of Justice (argued), Washington, D. C., for defendant-appellant.

Bruce I. Hochman (argued), Los Angeles, Cal., for plaintiff-appellee.

Before GOODWIN and SNEED, Circuit Judges, RENFREW, District Judge.

As Amended on Denial of Rehearing En Banc June 16, 1975.

OPINION

SNEED, Circuit Judge:

The Home Savings and Loan Association seeks a refund of income taxes which it paid as the transferee of the assets of Pasadena Savings and Loan Association and Savings and Loan Association of Anaheim pursuant to Notices of Deficiency issued on December 10, 1962. The Notice relating to Pasadena was based upon a restoration to the taxable period, January 1, 1956...

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