MR. JUSTICE MURPHY delivered the opinion of the Court.
This is a suit for refund of capital stock taxes paid by respondent for the years ending June 30, 1936, through 1939. We are asked to determine whether respondent was "carrying on or doing business" within the meaning of § 105 (a) of the Revenue Act of 1935, c. 829, 49 Stat. 1017, and subsequent acts, which provide:
"For each year ending June 30, beginning with the year ending June 30, 1936, there...
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