JOHNSEN, Circuit Judge.
Appellant sued in the District Court for recovery of alleged overassessments in his income taxes for the years 1942 and 1943. The Court gave summary judgment for the Government, on the ground that the admitted facts estopped appellant from asserting the existence of overassessments in the situation.
The overassessments were related to the income of a family partnership, comprised of appellant, his father, and their wives, whose reality...
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