GOODRICH, Circuit Judge.
Taxpayer, a Delaware corporation having its principal office at Vancouver, British Columbia, declared and paid in 1937, a dividend on its common stock of one share of its common stock and 66 cents in cash upon each 6½ outstanding shares. Most of its shareholders were citizens and residents of Canada. In its income tax return for the fiscal year ending June 30, 1937, taxpayer claimed a dividends paid credit, against the surtax on undistributed...
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