LINDLEY, District Judge.
The taxpayer petitions for a review of a decision of the Board of Tax Appeals, assessing additional taxes based upon a holding that the transaction hereinafter discussed was not a reorganization within the meaning of the Revenue Act. Two questions are involved: First, whether a stipulation between the parties that on December 31, 1926, petitioner "was a party to a reorganization" is decisive of the question as to whether or not the transaction...
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