STONE, Circuit Judge.
This is a petition to review a decision of the Board of Tax Appeals determining income tax deficiency against petitioner for the year 1932. The controlling issue is whether petitioner was an "association" within the meaning of Section 1111(a) (2) of the Revenue Act of 1932, 26 U.S.C.A. § 1696(3), reading "The term `corporation' includes associations, joint-stock companies, and insurance companies" and, as such, taxable as a corporation....
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