WILSON, Circuit Judge.
This is a petition for a review of a decision of the Board of Tax Appeals. On October 23, 1926, the appellee wrote the following letter to his wife, Mary Newbold Hale:
"Dear Mary: I wish to sell you the following shares in the Moa Bay Iron Company, and to be quite frank about the purpose and make this record of the whole matter.
"I sell you these shares with no string. They cease to be mine and become yours. Thus I establish...
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