COSTANTINO, District Judge.
Plaintiff, Doubleday & Co., Inc., commenced this action seeking a refund of corporate income tax in the sum of $1,423,328 plus interest arising from its 1977 tax year return.
The parties have submitted a detailed stipulation of facts as to all issues and both sides have filed cross-motions for summary judgment. For the reasons to follow defendant's motion for summary judgment is granted in all respects.
BACKGROUND<...
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