STEPHENS, Circuit Judge.
Taxpayer appeals from a District Court judgment in favor of the Collector of Internal Revenue.
Austin E. Griffiths, Jr., and his wife owned a dairy business which had assets valued at $60,685 and consisting of milk routes and dairy equipment. The business was incorporated on July 5, 1940, with an authorized capital of $50,000, represented by 14,000 shares of no par value preferred stock and 36,000 shares of no par value common stock...
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