SIBLEY, Circuit Judge.
Hughes Spalding was denied a claim of loss as realized in 1933 by a sale of land to his father accompanied by an option to repurchase. He paid the additional income taxes assessed and sued in the District Court to recover them as illegally collected. The answer denied that the sale was "a genuine and legal sale in contemplation of the federal income tax laws" and averred that "it resulted in no loss whatsoever within the meaning of the applicable...
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