HOLMES, Circuit Judge.
This appeal is from a judgment denying appellants relief in an action to recover deficiency income taxes and interest paid by them for the year 1944 in the respective amounts of $93,173.34 and $94,323.98. These are the pertinent facts:
In 1936, George B. Parr obtained an oil and gas lease which he transferred to Hamill & Smith, a partnership, with the
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