JOHNSON, District Judge.
This is a suit by the Dauphin Deposit Trust Company to recover $2,251.03 and interest, paid by it under protest for internal revenue stamps which the Collector required it to attach to certificates of participation drawn in a form set forth. The case was submitted to the court on a stipulation of facts.
The question is whether the certificates are taxable as corporate securities under the provisions of the Revenue Act of 1926, tit...
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