SPARKS, Circuit Judge.
The taxpayer petitions for review of a decision of the Board of Tax Appeals disallowing its claim for refund of $433.22, the total amount of taxes paid by it for the year 1932, which disallowance was based on principles of estoppel.
Petitioner sold property on the installment basis in 1929, utilizing the installment statute, section 44 (b) and (d) of the Revenue Act of 1928, c. 852, 45 Stat. 791, 26 U.S.C.A. § 44(b) note (d).
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