Sony Corporation of America v. The United States

OPINION

This excise tax refund suit was referred to Trial Commissioner Louis Spector with directions to make findings of fact and recommendation for conclusions of law under the Order of Reference and Rule 57(a) [since September 1, 1969, Rule 134(h)], The commissioner has done so in. an Opinion and Report filed October 9, 1969. Exceptions to the commissioner’s opinion, findings and recommended conclusion of law were filed by defendant. Plaintiff filed no exceptions and urged that the commissioner’s report be adopted. The case has been submitted to the court on oral argument of counsel and the…