MEMORANDUM OPINION
KEADY, Chief Judge.
In this tax refund suit based upon 28 U.S.C. § 1346(a), plaintiff, Farmers Grain Marketing Terminal (AAL), a Mississippi corporation with its principal place of business at Greenville, sues the United States for recovery of income tax deficiencies assessed by the Commissioner of Internal Revenue for the years 1971 and 1972, which were paid under protest.
The record before the court is presented upon stipulated...
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