MADDEN, Judge.
The plaintiff is a New York corporation organized in 1894. It has no capital stock, corporate shares, or certificates of ownership of any kind. It had a net income during the tax years 1945 through 1950, except the year 1947. It was taxed upon that income, and seeks to recover the taxes paid, on the ground that it was exempted from taxation by Section 101 (7) of the Internal Revenue Code of 1939, 26 U.S.C.A. § 101(7), which says:
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