BRATTON, Circuit Judge.
The question is whether for purposes of liability for income tax the sale of certain property was that of a corporation or of individuals who were its stockholders.
Section 22(a) of the Internal Revenue Code, 26 U.S.C.A. § 22(a), defines gross income to include among other things gains, profits, and income derived from sales or dealings in property. Section 311, 26 U.S. C.A. § 311, provides in substance that a transferee of...
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