Appeal of Enke City Dye Works, Inc.

*379OPINION.

In this appeal it is clear that there was a change of ownership after March 3, 1917, and it is equally clear that an interest or control of fifty per cent or more remained in the owner of the predecessor business. The provisions of section 331 of the Eevenue Act of 1918 are therefore applicable, and, under this section, the taxpayer is not entitled to include the claimed item of good will in its invested capital.