JONES, Circuit Judge.
The appellee, John H. Fewell, herein called the taxpayer, at the beginning of 1947, owned 35 shares and L. H. Simpson owned 36 shares of the capital stock of Petroleum Engineering Company, Inc. No other stock of the company was then outstanding. The taxpayer, in 1947, bought 35 of Simpson's 36 shares for $12,375. Taxpayer gave Simpson $4,000 in cash and agreed to pay the balance in 36 monthly installments with interest at five per cent. To raise...
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