BROWNING, Circuit Judge.
Having examined the record and the pertinent authorities, we are satisfied that the decision of the Tax Court must be affirmed.
1. We do not read the stipulation filed with the Tax Court as precluding consideration of evidence extrinsic to the documents of sale bearing upon the intent of the taxpayer and the purchaser; and, of course, the parole evidence rule could not have that effect as between the Commissioner and the taxpayer....
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