GARRECHT, Circuit Judge.
The question here is whether the distribution of $450 to the taxpayer from the Honolulu Oil Corporation, Ltd., hereinafter referred to as Honolulu constituted a taxable dividend. The taxpayer is suing to recover income taxes paid on this distribution in 1936.
The facts are stipulated and were adopted by the court below as its findings of facts.
On August 31, 1936, Honolulu liquidated three wholly owned subsidiaries and took...
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