OPINION OF THE COURT
SEITZ, Circuit Judge.
Taxpayers appeal a decision of the Tax Court sustaining a deficiency in income tax asserted against them for the year 1955 in the amount of $459,542.01. The Tax Court found that the taxpayers failed to sustain their burden of showing the incorrectness of the Commissioner's determination that the transfer of 27,000 shares of Bellanca Aircraft Corporation stock from the partnership of L. Albert & Son to the Winfield...
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