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ESTATE of Kenneth W. DAVIS, Deceased, Et Al., Etc., Petitioners-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellant
PER CURIAM:
The judgment is affirmed on the basis of the opinion of the United States Tax Court, Estate of Davis v. Commissioner of Internal Revenue, T.C.Memo. 1971-318 (1971), insofar as that opinion disposes of the Commissioner’s contention that this transaction was part gift, part sale.
Affirmed.