RUDKIN, Circuit Judge.
Between the years 1899 and 1902, the petitioner acquired all of the capital stock of the Modelo Oil Company, a California corporation, and loaned money to the corporation, taking notes therefor. Some time prior to March 1, 1913, the loans thus made reached an aggregate of $147,681.59. In 1921 the corporation sold all of its assets for the sum of $75,000, and the amount thus realized was paid to the petitioner, leaving an unpaid balance due on...
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