WOODROUGH, Circuit Judge.
This appeal is from a decision of the Board of Tax Appeals sustaining the Commissioner's determination of a deficiency of $4,512.68 in the petitioner's income tax for the calendar year 1927.
The petitioner is an Arizona corporation with its principal office in Kansas City, Mo. Prior to 1913 it acquired the title to certain mining property in Mexico, which it conveyed to the Tigre Mining Company, S. A., a Mexican corporation. All of...
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