KOELSCH, Circuit Judge:
The taxpayer, Gyro Engineering Corporation, appeals from a judgment of the district court denying its claim for refund of moneys paid pursuant to the Commissioner's determination of deficiencies in income tax for the years 1959 and 1960.
The dispute arose out of the transfer of three apartment house properties to Gyro by its two principal stockholders, Chris Mowry and Natalie, his wife.
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