HEALY, Circuit Judge.
The underlying question here is whether or not a certain investment trust was an association which, for tax purposes, should be treated as a corporation.
The question arises in this way: Respondents, whom for convenience we will call the taxpayer, owned certificates or shares of Deposited Insurance Shares, Series A, an entity created by an agreement and declaration of trust between Bank and Insurance Shares, Inc., called the depositor...
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