LINDLEY, District Judge.
The Commissioner of Internal Revenue levied against appellee an assessment for additional income taxes for the year 1927. Appellee paid the additional tax under protest; sued to recover, and obtained judgment in the District Court. This appeal followed.
The parties stipulated as to the facts. Appellee, in 1919, purchased from one West certain formulæ for $100,000, paying therefor by shares of its own capital stock. West agreed...
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