Court of Appeals for the Second Circuit January 16, 1933, 17 (United Business Corporation v. Commissioner of Int. Rev.)

L. HAND, Circuit Judge.

The petitioner is a corporation organized on April 1, 1920, to take over real property in Seattle, conveyed to it by one Smith, its sole shareholder, except for a few shares to qualify directors. During the year Smith also transferred to it a large number of shares of stock, which he had held for some time before; and still more in 1921.