SIBLEY, Circuit Judge.
On his income tax return for the year 1934, Richard W. Courts was assessed additional taxes on $103,671 of gain which the Commissioner held had been realized and not returned. The tax was paid, refund was sought and not obtained, and the Collector was sued in the District Court with success; and this appeal follows.
The facts are stipulated and in outline are these: In July, 1929, Courts was an applicant for membership in the New York...
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