GARZA, District Judge.
This is a suit for refund of federal income taxes paid by plaintiffs to defendant.
All of the facts have been stipulated, and the case has been submitted to the Court on written briefs and on oral argument.
A brief summary of the stipulated facts is as follows:
Plaintiff taxpayers were shareholders of Rio Development Company, a Texas corporation, which in 1955 was engaged in the land development business in the Rio Grande...
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