GRIM, District Judge.
Two life income beneficiaries of a trust created by the will of Cecelia S. Brill, who died in 1937, have brought these actions to recover certain income taxes assessed against them for the year 1947 and paid.
When the trust was created in 1937 it owned 1,690 shares of $100 par value cumulative preferred stock of The Brill Corporation, appraised at that time at $38 a share, a total of $64,220. In 1944, following a merger of The Brill Corporation...
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