HAMILTON, Circuit Judge.
This appeal involves a deficiency in income taxes for the calendar year 1929 found by the Board of Tax Appeals to be due from the estate of R. R. Ellis. The applicable statute is the Revenue Act of 1928, Section 22, Ch. 852, 45 Stat. 791, 797, 26 U.S.C.A. § 22, which provides, among other things, that "gross income" includes gains in whatever form paid from dealings in property.
The Van Fleet-Ellis Corporation of Delaware had...
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