MEMORANDUM OPINION
GLEN M. WILLIAMS, District Judge.
This is an action brought by a Subchapter S corporation (hereinafter "Sub-S") seeking a refund, with interest, of a $699,848.69 payment of income tax for the year 1974 assessed by the Commissioner of the Internal Revenue Service at the corporate level although the shareholders of the corporation had reported and paid taxes upon the earnings of the corporation on their individual tax returns. Jurisdiction...
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