L. HAND, Circuit Judge.
This is a petition filed by the taxpayer to review an order of the Board of Tax Appeals assessing a deficiency against it in its income, excess profits, and "personal holding company," taxes for the year 1935. The question is as to the validity of a deduction claimed by the taxpayer, as to which the relevant facts are as follows. The taxpayer held all the shares of a subsidiary, known as Seven Eleven Fifth Avenue, Inc. — 2,500 with a...
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