FRIENDLY, Circuit Judge.
Taxpayers' petitions seek review of a decision of the Tax Court upholding determinations of the Commissioner that certain distributions to taxpayers as stockholders in two corporations, Kew Terrace, Inc., and Kew Terrace No. 2 Corp., in 1950 and 1951 were taxable "as gain from the sale or exchange of property which is not a capital asset" under § 117(m) relating to collapsible corporations, added to the Internal Revenue Code of 1939 on...
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