OPINION
WALLACE, Circuit Judge:
The IRS assessed an accumulated earnings tax deficiency against Starman under Int.Rev.Code § 531. The company paid the tax and filed suit in the district court for a refund. The district court granted judgment for the taxpayer and the government filed a timely notice of appeal. We affirm.
The Starman stock is held by four brothers and their uncle, all of whom were active in the company's business. Before 1968...
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