ROCHE, District Judge.
Plaintiffs sue for a partial refund of a total stamp tax of $27,308.35 paid by the Intercoast Trading Company, a corporation now dissolved, on an original issue of its capital stock. Stock certificates representing the entire issue of 1,800,000 shares without par value were issued from September 10, 1929, to October 22, 1929.
Under Schedule A, subdivision 2, of the Revenue Act of 1926 (section 800 et
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