PER CURIAM.
This is an appeal from an order granting a motion for summary judgment made by the United States in a suit brought by a corporate taxpayer for a refund of federal income taxes.
In 1964, appellant, a corporate taxpayer having several subsidiaries filed a consolidated income tax return with them in accordance with the provisions of section 1501 of the Internal Revenue Code of 1954, 26 U.S.C. § 1501. This section provides in relevant part:
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