GARRECHT, Circuit Judge.
In 1927, 1928 and 1929, Clayton R. Jones acquired 235 shares of the stock of the Hibernia Commercial & Savings Bank of Portland, Oregon, for himself, and 70 shares for W. J. Jones & Son, Inc., a total of 305 shares. The 235 shares of said stock cost Clayton R. Jones $32,920, and the 70 shares thereof cost W. J. Jones & Son, Inc., $12,000.
The Board of Tax Appeals made findings of fact, substantially as follows:
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