L. HAND, Circuit Judge.
The Tax Court held that for the years 1932, 1933 and 1934, the taxpayer must use as a "basis" for the depreciation of certain patents which it owned, their cost to other corporations from which the taxpayer had acquired them; the taxpayer insisted that the proper "basis" was its own cost at the time of acquisition. The issues on which the question turns are two: (1) whether the Commissioner was estopped as to the "basis" by certain earlier...
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