Mr. Justice CLARK:
Appellants seek the refund of income taxes paid on a 1963 tax deficiency assessed against them by the Commissioner of Internal Revenue. The tax liability claimed arose out of the liquidation of a partnership ranching business of the appellant, Owen Austin, and his former wife, Frances. The transferred liabilities of Owen Austin at the time of liquidation exceeded the adjusted basis of his assets in the partnership and a tax deficiency was levied...
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