TEHAN, Chief Judge.
The plaintiff taxpayer, a Wisconsin corporation engaged in the business of fur fox ranching, reported as ordinary income on both its income tax and excess profits tax returns for the year 1944, the amount realized from the sale of pelts of breeder foxes which had been held in its breeding herd for more than six months. It filed timely claims for refund, disallowed by the defendant, in which it asserted that the gain realized from the sale of pelts...
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