KUNZEL, District Judge.
This cause was submitted for decision upon written stipulation of facts, which facts are hereinafter set forth.
Cate Ditch Company is a California corporation organized to operate an irrigation ditch company for the benefit of its member stockholders; and from 1930 until 1956 it enjoyed the status of a tax-exempt corporation under I.R.C. § 501(c) (12), 26 U.S.C.A. § 501(c) (12). In 1956, contemplating dissolution, the taxpayer...
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