SAWTELLE, Circuit Judge.
This petition for a review of a decision of the Board of Tax Appeals involves deficiencies in income taxes asserted against the petitioners as transferees and beneficiaries of the Dominguez Harbor Tract No. 2 for the years 1923, 1924, and 1925. There is no dispute as to the facts, and counsel in their respective briefs have adopted the findings of fact as made by the Board of Tax Appeals. These findings are as follows:
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