WISDOM, Circuit Judge.
This tax case is before us for the second time. On the first appeal, we held that a certain tankship was a capital asset and that the appellant here, Williams, realized capital gain from the sale of the tanker. Williams bought the vessel, partially completed, more than six months before the sale. The vessel was enlarged and completed less than six months before the sale. We remanded the case to the Tax Court to allocate the taxpayer...
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