POPE, Circuit Judge.
The facts which concern this review are set forth in the Findings of Fact of the Tax Court as follows:
"On or about August 10, 1937, J. I. Morgan acquired an `Accumulative Investment Certificate,' Series F.-232668, from Investors Syndicate (presently known as Investors Diversified Services, Inc.) of Minneapolis, Minnesota. Under the terms of the certificate, the issuing company agreed to pay to Morgan (with certain options) at the expiration...
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