L. HAND, Circuit Judge.
The petitioner was a corporation, the successor to a firm of the same name; it was organized on April 1, 1919, and took over the firm property on May twenty-fourth of that year in exchange for preferred stock issued to the partners. These had already on January eighth filed individual income tax returns for their shares in the firm income for the year 1918, and a firm return for excess profits tax, and they paid the amounts returned on January...
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