MANTON, Circuit Judge.
The petitioners, executors of the estate of Edwin D. Metcalf, appeal from the determination of the Board of Tax Appeals, which held they must pay an income tax on the sale of rights in 1921. Rev. Act 1926, c. 27, 44 Stat. 9, 109, 110. The decedent was a stockholder of the Southern Pacific Company and his executors received purchase rights to shares of stock of the Pacific Oil Company under the following circumstances:
On December 1,...
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