GARDNER, Circuit Judge.
This is a petition to review a decision of the Board of Tax Appeals which sustained a redetermination by the Commissioner of individual income tax liability of petitioner, George B. Clifford, Jr., for 1934. The facts were stipulated, and hence are not in dispute. So far as here material, they are substantially as follows:
On June 20, 1934, petitioner executed a declaration of trust by which he acknowledged that he held certain securities...
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