BOOTLE, Chief Judge:
Plaintiff (corporate-taxpayer) brings this action pursuant to 28 U.S.C.A. § 1346(a) (1), for a refund of income taxes paid, claiming that the Commissioner erroneously determined that property transferred to plaintiff by its incorporators-sole stockholders constituted a contribution to capital rather than a sale.
The controlling facts are undisputed. On March 2, 1964, Mr. Country Johnston purchased 465 acres of land in Valdosta, Georgia...
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