GOODRICH, Circuit Judge.
The sole question involved in this petition for review of a decision of the Board of Tax Appeals is when a dividend becomes income to a shareholder of a corporation. The taxpayer, a Rhode Island corporation, has its general office in Pittsburgh, Pa. In 1936 it owned shares in another corporation. In October, 1936 this corporation declared a cash dividend payable on January 2, 1937 to shareholders of record at the close of business on December...
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