SMITH, Chief Judge.
In these three cases money received by the taxpayers on the redemption of shares of second preferred stock in I. Newman & Sons Inc. and in the case of Northup on sale of such preferred stock to his daughter, Jean N. Miles, and to a trust of which she was the beneficiary were treated in the taxpayers' returns as capital gains. The Commissioner held that the full amount received on redemption and sale of the shares should be treated as dividend...
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