ROBB, Associate Justice.
Appeal from a decision of the Board of Tax Appeals assessing additional income and profit taxes.
Appellant corporation is located at Corning, N. Y., and was organized in December, 1911, under the laws of that state, with a corporate life of 50 years from date of organization. In December, 1920, being in need of money on account of large increase in business, and being unable to borrow from banks, appellant determined to issue preferred...
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