EVANS, Circuit Judge.
Petitioner assessed respondent with a deficiency income tax for the taxable year 1919, the amount of which was based upon the sum he received through the liquidation of the Iowa-Burk Syndicate of which he was the owner of a beneficial interest. The propriety of the additional tax turns upon whether the syndicate was taxable as a corporation or as a trust.
A stipulation of facts tells the story of this venture.
In 1918, four men...
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