FITZPATRICK, District Judge.
Plaintiff brings this action for recovery of federal income taxes in the amount of $552,219.51 plus interest paid, alleged to have been erroneously and illegally assessed and collected by Defendant through its agents. The case was tried before the court sitting without a jury on February 3, 1989. The court heard final argument in the case on June 21, 1989. The court's findings of fact and conclusions of law are set out below.
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