PER CURIAM:
Bank of America National Trust and Savings Association ("Trustee") as trustee of the Fox Oil Company Trusts ("Taxpayer") sued for a refund of taxes overpaid during 1969-1971, claiming that the Government improperly characterized the Taxpayer as an "association" taxable as a corporation under Internal Revenue Code §§ 7701(a)(3), 11(A). The district court held that the Trustee was foreclosed from relitigating the issue by reason of this court's...
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