MEMORANDUM
MEREDITH, Chief Judge.
This claim for income tax refund was tried to the Court on November 21, 1977. In accordance with Rule 52(c), F.R.C.P., 28 U.S.C., the Court makes the following findings of fact and conclusions of law.
In 1965 the plaintiff entered negotiations with Elot H. Raffety Farms, Inc., and L. D. Joslyn (an owner of one-third of plaintiff's stock), in order to consider the prospects of cotton farming in the Republic of Mexico...
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