BRENNAN, District Judge.
This appeal questions the taxable status of the alleged overpayment by the taxpayers of income tax for the calendar year 1945. The facts are not complicated; the issue of law is concise.
At the times pertinent here, George W. Hartfield and Edwin E. Healy were officers of the Hartfield-Healy Supply Company, Inc., a New York corporation, and each was the owner of twenty-five of the fifty-two outstanding shares of stock. In 1945 the corporation...
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