WRIGHT, Circuit Judge.
In 1959, respondent ACF Industries sold an unincorporated division of its operations, referred to as Nuclear Reactor Engineering Organization, to Allis-Chalmers Manufacturing Company. The agreed purchase price was the book value of the assets held by the Organization plus $300,000. In computing its District of Columbia Franchise Tax for the year of the sale, ACF treated the transaction as a sale of a capital asset giving rise to no tax liability...
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