GARDNER, Chief Judge.
Appellants, who are husband and wife, for the taxable year 1948 filed a joint income tax return. In due course, on October 23, 1952, the Director of Internal Revenue made a deficiency assessment in the amount of $9,799.44. This deficiency assessment was bottomed on the fact that Dorothy Owen Knop had during that taxable year sold to her brother, Edward Owen, for $43,500 one hundred forty-five shares of the capital stock of the Paxton & Vierling...
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