RIDDICK, Circuit Judge.
The United States appeals from a judgment in an action brought under Title 28 U.S.C. § 1346(a) (1), to recover alleged overpayments of income taxes for the years 1944, 1946, and 1947.
The taxpayer raises beef cattle for market. In accordance with custom in the industry, the taxpayer maintained a herd for breeding purposes, from year to year selling steers on the market, but retaining the heifers not for sale but to replenish his...
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