BARNES, Circuit Judge.
This is an appeal from a decision rendered against the taxpayer on his cause of action seeking a refund for income taxes paid under protest. 28 U.S.C. § 1346(a) (1); Int. Rev. Code of 1954, § 7422, 26 U.S.C. § 7422. It covers the period May 1, 1951, to April 30, 1952. Appellant sold growing crops on leased land. The land had been leased for more than six months. Plaintiff sold the growing crops and the lease to the same party...
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