STEWART, Circuit Judge.
The sole issue to be determined on this review is whether amounts distributed to the petitioners in 1948 by a closely held corporation were taxable as ordinary income or as a long term capital gain. The Tax Court found that the amounts in question were distributed as "boot" pursuant to a plan of reorganization, having "the effect of the distribution of a taxable dividend" under section 112(c) (2) of the Internal Revenue Code of 1939, 26 U.S...
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