GARRECHT, Circuit Judge.
The question before the court on this appeal is whether the Documentary Stamp Tax imposed upon the transfer of corporate stocks by Title VIII, Section 800, Schedule A-3 of the Revenue Act of 1926, as amended, 44 Stat. 9, 99, 101; 47 Stat. 169, 273; 48 Stat. 206, § 212; 49 Stat. 431; 49 Stat. 2029; 50 Stat. 358, 26 U.S. C.A. Int.Rev.Acts, page 289, should be computed on the basis of the par or face value of the certificates surrendered...
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