O'CONNELL, Circuit Judge.
In 1925, petitioner inherited real estate valued at $67,000 in the decedent's estate tax return. In 1927, she sold the property. The sale price was $97,500, of which $27,500 was paid in cash and the remaining $70,000 was covered by a purchase money bond and mortgage bearing 6% interest. She did not report the taxable gain in either her 1927 or any subsequent income tax return.
In 1932, on the due date of the mortgage, the purchaser...
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