LITTLETON, Judge.
The first question presented is whether distributions by a corporation in payment of accumulated dividends on its preferred stock in the years 1937 to 1940, inclusive, to the extent that they represented distributions out of appreciation in value of property existing on March 1, 1913, and realized thereafter, were exempt from income tax, as claimed by plaintiff, or were taxable to the extent that they exceeded the basis of the stock, as claimed by...
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