POSNER, Circuit Judge.
This is a suit for refund of federal income tax. The district court granted summary judgment against the taxpayer, Thomas Dower, and he appeals.
Dower, James Gleeson, and another man were the original stockholders of the Russell Packing Company, a meat-packing concern. In 1952 they entered into an agreement with certain employees of the company (the "Key Men"), including Gleeson, obligating the Key Men to purchase Dower's stock either...
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