STEPHENS, Circuit Judge.
William D. Noland, plaintiff-appellant, personally and in the capacity of a trustee of a charitable trust entitled "Dr. William D. Noland Trust Estate, Ltd.", appeals from a summary judgment in favor of Harry C. Westover, Collector of Internal Revenue at Los Angeles, California, (Sixth Collection District of California), a defendant-appellee, and against Noland in each capacity alleged, and from a summary judgment in favor of George D. Martin...
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