FOLLMER, District Judge.
Suit was instituted for the refund of $4,398.57 representing one-half of a total of $8,797.14 taxed by the Government under Section 1802(a) of the Internal Revenue Code, 26 U.S.C.A. § 1802(a) as the cost of documentary stamps on an issue of 79,974 shares of preferred stock. The transaction was in December 1946, and prior to the 1947 Amendment to Section 1802(a) supra, which became effective August 8, 1947. Plaintiff has filed a motion...
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