SPARKS, Circuit Judge.
This is a petition for review of a decision of the Board of Tax Appeals pursuant to sections 1001 and 1002 of the Revenue Act of 1926, c. 27, 44 Stat. 9, 109, 110. USC Supp. VI, title 26, §§ 641, 642 (26 USCA §§ 1224 and note 1225). That decision affirmed a determination of the Commissioner that there was a deficiency in income tax due from petitioner for the year 1922 in the sum of $20,557.96.
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