WOODBURY, Circuit Judge.
The plaintiff's testator died on April 26, 1937, owning 2,250 shares of stock in the North Vancouver Land & Improvement Company, Ltd. (hereinafter called the Company), a corporation organized under the laws of British Columbia. On July 16, 1938, the plaintiff filed an Estate tax return in which he listed the above shares of stock as having no value. The Commissioner, however, considering the net value of the assets of the Company (land...
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