HANEY, Circuit Judge.
Petitioner seeks review of a decision of the Board of Tax Appeals holding that a stock dividend received by him was taxable income.
Sprouse-Reitz Co., Inc., was organized under the laws of Oregon on February 20, 1920. On February 13, 1936, its capital stock, authorized and issued, was as follows:
Class Authorized Issued ----------------------------------------------------- $100 par voting...
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