RAYMOND, District Judge.
Plaintiffs have brought suit to recover the sum of $3,713.78 paid upon determination by the Commissioner of Internal Revenue of a deficiency in the income tax returns of deceased for the year 1919. The deficiency resulted from the finding by the commissioner that payments of $24,000 made to the taxpayer in 1919 by the Furniture Exhibition Building Company were dividends and not loans. On the date of paying the tax, namely, February 11, 1925...
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