WALLER, Circuit Judge.
The facts are well stated by the Tax Court as follows:
"Petitioner is a Georgia corporation with its principal office at Macon, Georgia. It filed its income tax returns for the years in question with the collector of internal revenue for the district of Georgia. In 1930 A. M. Peeler was the sole stockholder of the petitioner with the exception of 4 qualifying shares in the hands of the directors. The Dunlap sisters were the sole stockholders...
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