HALBERT, District Judge.
Central Valley Grocers, Inc. (hereinafter referred to as Grocers), a California corporation engaged in the wholesale grocery business, transferred its real property, together with related prepaid expenses, to Central Valley Management Corp., plaintiff herein, on January 2, 1951. Concurrently the building involved was leased back to Grocers.
Subsequently both plaintiff and Grocers availed themselves of the surtax exemption and the minimum...
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