DOBIE, Circuit Judge.
The facts in this case were stipulated as follows:
"1. Syndicate Varieties (hereinafter called taxpayer), is a corporation organized under the laws of Great Britain with its principal office at Cranbourn Mansions, Cranbourn, London, W. C. 2, England. During the year 1936 it did not have an office or place of business nor was it engaged in trade or business within the United States.
"2. During the last half of the year
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