THORNTON, District Judge.
Both parties have filed motions for summary judgment and are in agreement that there is no dispute as to the facts.
Norwalk Corporation, a personal holding company, was dissolved as of May 31, 1946, and all of its assets and property were distributed at that time in equal shares to its two stockholders in complete liquidation of the corporation. These stockholders paid the tax on their respective capital gains amounting to $96,104...
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