CHASE, Circuit Judge.
The Commissioner determined the income taxes for 1937 and 1938 on the United States income of the petitioner, a Scotch Corporation, under the provisions of § 231(a) of the Revenue Act of 1938, 26 U.S.C.A. Int.Rev.Acts, page 1097, as though it were a non-resident. The petitioner contended that it was entitled to be treated as a resident and have such taxes assessed at the rate provided in subsection (b) of the above section of the statute...
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