WILLIAMS, Judge.
The plaintiff, a Georgia corporation, during the year 1917, owned all the capital stock of the Fulton Bag & Cotton Mills of Brooklyn, N. Y., a New York corporation. The latter corporation was dissolved in January, 1918, and all its assets and liabilities were taken over by the plaintiff.
On March 27, 1918, the plaintiff filed with the collector of internal revenue at Brooklyn, N. Y., the income and excess profits tax return for its subsidiary...
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