MEMORANDUM OPINION AND JUDGMENT
STEVENS, District Judge.
This action for recovery of federal income taxes is before the court on cross motions for summary judgment based on the Standard Pretrial Order No. 2 and Stipulation of Uncontroverted Facts. This court has jurisdiction under 28 U.S.C. § 1346(a)(1).
Plaintiff Stahl Speciality Company, a Missouri corporation, manufactures and sells a variety of aluminum castings and
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