POPE, Circuit Judge.
Petitioners are husband and wife, residents of California, who filed their income tax returns for the calendar year 1945 on a community property basis. The controversy present here arises out of the claim of Paul W. Trousdale, here called the petitioner, that a sum of $112,000, realized by him from a purported "assignment" of his interest in a partnership, represented income from the sale of a capital asset. These income tax returns reported the...
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