L. HAND, Circuit Judge.
This appeal (petition to review) is from an order of the Board of Tax Appeals fixing a deficiency in the taxpayer's income tax for 1928, under the following circumstances: In October, 1927, he bought the shares of three small lighting companies in Vermont, and all the assets of a fourth. For all four he paid $96,000, and he at once organized a separate company to which in consideration of all its shares he conveyed the assets of the fourth...
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