KERRIGAN, District Judge.
This is an action to recover $185,176.60, which was paid on an additional assessment of income tax for the year 1917. In December, 1917, plaintiff received 6,000 shares of the Filoli Estate, Inc., a family corporation, in return for the transfer to it of various properties determined by the Commissioner of Internal Revenue to have cost him, or had a value on March 1, 1913, of $609,719.08. At the same time, 28,500 shares of the Filoli Estate...
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