CHASE, Circuit Judge.
The petitioner is a foreign corporation organized under the laws of Puerto Rico where it was engaged during its taxable calendar year 1935 in selling coal. It sustained a net loss in that part of its business. It now admits that its stock was so held, however, that it was a personal holding company within § 351(b) (1) (A) of the Revenue Act of 1934, 26 U.S.C.A. Int.Rev. Acts, page 757, provided it derived at least 80 per centum of its gross...
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