SIMONS, Circuit Judge.
The petition for review and the appeal involve the same question in a controversy between substantially the same parties. They were argued together, and may be disposed of in a single opinion. The issue is whether the assignee of corporate property, engaged in its orderly liquidation, is required, under the provisions of § 52 of the Revenue Acts of 1934 and 1936, 26 U.S.C.A. Int.Rev.Code, § 52, to make a corporate income tax return...
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