KOELSCH, Circuit Judge.
This is an appeal by the Director of Internal Revenue from a judgment of the United States District Court in favor of the taxpayer, M. Robert Guggenheim, Jr., in the latter's suit to recover a portion of the sum paid by him as income tax for the years 1954 and 1955.
Plaintiff's claim is that the twenty-four monthly payments made by him to Jean Guggenheim in the two taxable years mentioned were within the purview of those portions of...
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