CHASE, Circuit Judge.
The taxpayers, as residuary devisees under the will of their father, took a parcel of real estate comprising the land and buildings of a hotel situated in the state of New York which was called his Lake Mohonk property and which will be so designated herein. The two formed a partnership that operated the hotel from February 15 to December 31, 1930, at a profit. The partnership had net income distributable to each partner in that year in excess...
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