REILLY, Chief Judge, Retired:
This is an appeal by Capital Holding Corporation from a judgment denying a refund of corporate franchise (income) taxes in the amount of $273,114.29 for the years 1970, 1971, and 1972, assessed pursuant to D.C. Code 1973, § 47-1571a.
The appellant (Capital), a corporation with its only office and place of business in Louisville, Kentucky, owns substantially all
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