BONE, Circuit Judge.
The question on these appeals is whether the taxpayers, John A. Lesoine and L. J. Marcus, are entitled to refund of income taxes paid by them for the years 1942-1943.
The material facts were stipulated. In 1942 each of the taxpayers owned one-half of the total authorized and outstanding stock of Marcus-Lesoine, Inc., a California corporation.
Marcus-Lesoine, Inc. declared ordinary dividends of $40,000 on November 30, 1942, and...
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