CLARK, Circuit Judge.
The first point on this appeal concerns the validity of a claim against an estate in bankruptcy for certain sales and business taxes levied by the City of New York against the bankrupt. The trustee concedes the validity of such taxes as were levied upon the bankrupt's sales of machinery manufactured by it, but contests the tax levied on its purchases of materials. But, as stated in the opinion below, D.C.S.D.N.Y.,
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