GARRECHT, Circuit Judge.
This case turns on the question of whether or not a "distribution in liquidation," alleged to have been made to the stockholders of a corporation during a winding-up process that was carried out with the formation of a new corporation in view, amounted to a "taxable dividend paid" entitling the outgoing corporation to a credit under the Revenue Act of 1936.
The appellees brought suit as liquidating trustees of the Pommerelle Company...
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