BRYAN, Circuit Judge.
In January, 1927, petitioners Leopold Adler and his wife, principal stockholders of I. Epstein & Bro. Co., received $50,000 and $47,500, respectively, as their shares of a distribution made upon the redemption of a part of the preferred stock of that company, which was issued in 1924 as a 100 per cent. dividend upon common stock and made redeemable after two years. In their income tax returns for 1927 they accounted for the amounts so received...
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