DAWKINS, District Judge.
These two cases involve appeals by the Commissioner of Internal Revenue from the adverse rulings of the Board of Tax Appeals upon asserted liability of the respondents for additional income taxes. They were tried and disposed of as one case by the board and will be treated in the same manner here.
The facts were stipulated, and we quote and adopt the board's summary thereof as follows:
"1. The petitioners, S. B. and Charles...
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