PER CURIAM.
Petitioner seeks review of a decision of the Tax Court. The facts may be briefly summarized as follows: In the year 1913 petitioner's mother loaned $400,000 to the Van Nuys Building Company, a family corporation then owned one-half by the mother and one-sixth by each of her three children, which loan was evidenced by a three year note bearing 5% interest per year, secured by an unrecorded mortgage. Between 1915 and 1920 the mother told her children at...
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