ALDRICH, District Judge.
The petitioners sue for refund of income taxes for the taxable year 1950. The only question is a single one on the merits. The facts have been stipulated and I find them to be in accordance with the stipulations filed by the parties and supplemented orally in open court.
In 1947 petitioners were substantial shareholders in the Braemore-Kenmore Trust, a Massachusetts trust having transferable shares. In that year the trust was reorganized...
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