Opinion by
Cole, J.It was.stipulated that the medicinal preparations are the same in all material respects as those passed upon in Wing Duck Co. v. United States (6 Cust. Ct. 133, C. D. 446) and Shun Yuen Hing & Co. v. United States (11 Ct. Cust. Appls. 331, T. D. 39143), which records were incorporated heroin. The merchandise was therefore held not subject to the internal revenue tax.