COLEMAN, Circuit Judge.
This is a suit for the refund of $473,641.70 in federal income taxes ($348,050.14 in taxes, plus $125,591.56 interest). The State National Bank of El Paso, the suing taxpayer, is Trustee for the Lee Moor Children's Home. This, undoubtedly, is a charitable trust. The trust owned a 2875 acre irrigated farm in El Paso County, the largest farm in the County. The annual cost of operating the farm was $800,000. The necessary equipment was valued...
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