MEMORANDUM OF OPINION
FINDINGS OF FACT AND CONCLUSIONS OF LAW
WESLEY E. BROWN, District Judge.
In this action, tried to the Court, plaintiff seeks a refund of federal income taxes and interest paid, arising from the defendant's disallowance of deductions claimed by plaintiff on its 1968, 1969, 1970 and 1971 federal income tax returns.
The action arises out of a 1956 loan transaction, in which plaintiff borrowed $6,250,000.00 from the Northwestern...
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