SIBLEY, Circuit Judge.
This is a test case to determine the effect on the income taxes of stockholders of a national bank, produced by a recapitalization in the tax year 1937. The American National Bank of Pensacola, Florida, had capital in excess of its needs, and a plan to reduce it was submitted to and approved by the Comptroller of the Currency. Pursuant thereto, on due corporate proceedings, the eight thousand shares, par value $100.00, were reduced to four thousand...
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