Memorandum Findings of Fact and Opinion
BRUCE, Judge:
A former decision by us in this proceeding entered September 7, 1951, determining the issues in favor of the respondent, was reviewed by the United States Court of Appeals for the Fourth Circuit. By the opinion of that court on June 19, 1952, this Court was sustained in its holding that the gain realized by the petitioner as a result of the transactions here involved did not constitute a gift to him....
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