SIBLEY, Circuit Judge.
W. R. Prescott and Mrs. W. R. Prescott in 1929 exchanged 400 shares of common stock in Coca-Cola International Corporation for 800 shares of common stock of Coca-Cola Company. They sold part of the shares received, and, realizing a gain thereby, paid a tax thereon. They have been assessed additionally for a corresponding gain in respect to the shares they did not sell.
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