GOODRICH, Circuit Judge.
This litigation concerns the taxpayer's liability for personal holding company surtax for the years 1939 and 1940. It comes to us on an appeal from the decision of the Tax Court in favor of the Commissioner. The taxpayer here concedes all but two points settled against him by the decision of the court below.
The first point is that the Transportation Service Associates, Inc., distributed its assets in kind in complete liquidation ...
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