GARDNER, Circuit Judge.
This matter is before us on petition to review a decision of the Tax Court which held the petitioner liable for deficiencies in income taxes for the taxable years 1938 to 1941, both inclusive.
The basic facts are not in dispute. Petitioner has engaged in the operation of motion picture theaters for about thirty years. From 1933 to 1937, both inclusive, he operated a circuit of from nine to thirteen theaters under a partnership agreement...
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