WILLIAMS, Judge.
The plaintiff seeks to recover $82,634.09, an alleged overpayment of his income taxes for the year 1923, with interest thereon from date of payment.
The challenged taxes were imposed under authority of the Revenue Act of 1921 (42 Stat. 227), as amended by the act of March 4, 1923 (42 Stat. 1560).
The facts, about which there is no controversy between the parties briefly stated, are:
The plaintiff, on January 8, 1912, acquired...
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