GILBERT, Circuit Judge.
The plaintiff in error was for many years extensively engaged in the business of buying wines and brandies from wine makers in California, and selling the same, generally in carload lots, to wholesale dealers. His business was in the nature of that of a broker. He had no capital invested in it, except that occasionally he would loan money to grape growers to finance the raising of their crops. In his income tax returns for 1919 and 1920 he...
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