WOODROUGH, Circuit Judge.
This is an appeal from a decision of the Board of Tax Appeals rendered on a stipulation of facts involving income taxes for the years 1925 and 1926 in four cases consolidated in the proceedings before the Board (28 B. T. A. 176). The essential facts are as follows: Sid Umsted, a resident of Camden, Ark., died intestate on November 3, 1925, the owner of certain oil and gas properties and royalty interests in oil and gas lands in Ouachita County...
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