SIMONS, Circuit Judge.
The appellee obtained judgment below for recovery of income taxes for 1922 collected under a deficiency assessment by appellant's decedent, collector of internal revenue. The assessment resulted from the disallowance of a deduction taken by the taxpayer for loss incurred on land in the Bitter Root Valley, Mont., purchased in 1912.
The land, in which the taxpayer had a half interest, was arid and undeveloped, was purchased for resale...
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