COLLET, Circuit Judge.
This action is to review a decision of the Tax Court of the United States sustaining the action of the Commissioner of Internal Revenue in making a deficiency income tax assessment against the estate of Ker D. Dunlop. The facts are not in dispute. Those material to the issues presented are as follows.
Mr. Dunlop was a resident of St. Paul, Minnesota, and died there intestate on May 26, 1939. He was survived by a widow, Jane C. Dunlop...
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