PAGE, Circuit Judge.
This is a petition for review of the decision of the Board of Tax Appeals, confirming respondent's assessment against petitioner for income taxes for the years 1917, 1918, 1919, and 1920.
The taxes were assessed on the theory that petitioner is a trust, taxable under the provisions of section 2(b) of the Revenue Act of 1916 (39 Stat. p. 757) and section 219 of the Act of 1918 (40 Stat. p. 1071), and not an association within the provisions...
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