McDERMOTT, Circuit Judge.
The petitioner appeals from a decision by the Board of Tax Appeals as to three items involved in its income tax returns for the years 1922 and 1923. The petitioner was organized in 1919 to acquire a patent application for an automobile lock and to manufacture and market the same. At the time of its organization, the application for patent had proceeded to the point where it was reasonably certain that its allowance would shortly be accomplished...
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