HUTCHESON, Circuit Judge.
Petitioner returned as income received by the estate only one half of the dividends on its stock which Hughes Tool Company declared and credited to him as administrator in 1924 and 1925. He advances three reasons for not having returned the other half as income: (1) That the dividends, though credited, were not then nor were they ever in fact actually received by the estate. That he never appropriated them, and they were canceled in 1926...
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