BORAH, Circuit Judge.
This is an appeal by W. Sam Edwards, administrator of the Estate of Marion H. Allen, former Collector of Internal Revenue for the District of Georgia, from a judgment of the District Court granting a refund of additional income taxes paid by appellees pursuant to deficiencies determined against them by the Commissioner. The tax years involved are 1945 to 1949, inclusive. The deficiencies were determined by the Commissioner by attributing to each...
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