PELL, Circuit Judge.
This case involves a claim for refund of federal income taxes. The plaintiff filed a complaint in the district court seeking recovery of the taxes paid for the years 1963 and 1965 through 1971. The parties, following the filing of the defendant's answer, submitted the case for decision on the basis of a stipulation of facts. Both parties filed motions for summary judgment. The district court granted summary judgment to the defendant and this appeal...
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