HUTCHESON, Circuit Judge.
In 1936, the tax year in question, Turney, hopelessly insolvent, was indebted to Pacific National Agricultural Corporation, in the sum of $101,866.10, secured by mortgage on cattle, livestock and equipment, having a cost basis of $9,600 and a value certainly not exceeding the debt. On October 2nd of that year, by a carefully worked out arrangement with the mortgage creditor, he surrendered the security to it, and received in return, a cancellation...
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