MATHEWS, Circuit Judge.
This is a petition brought by the Commissioner of Internal Revenue to review a decision of the Board of Tax Appeals holding that respondent's income tax liability for the year 1930 was $330.98 less than the Commissioner had determined it to be. The facts are as follows:
Respondent owned 165 shares of the preferred stock of Columbia Steel Corporation, some of which she purchased in 1924 and some in 1926. The total price paid by respondent...
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