Memorandum Findings of Fact and Opinion
The only issue in the case is whether a distribution to Mary B. Booth in 1948 on account of an assessment on stockholders of a national bank, the right to which distribution was acquired by her as a result of the liquidation of a corporation which had paid the original amount assessed, is to be treated as long-term capital gain or ordinary income.
The proceeding, insofar as it related to the year 1949, was dismissed...
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