TUTTLE, Circuit Judge.
The sole question here is whether the district court erred in holding that the conveyance of a warehouse property to the taxpayer corporation by its sole stockholder, in form a sale, was in substance a contribution to capital. We deem it appropriate here to set forth verbatim the findings of fact and conclusions of law of the district court, 54-2 U. S. Tax Cases ¶ 9528:
"1. The Court has jurisdiction of the parties and subject matter...
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