ALLEN, Circuit Judge.
This is a petition to review a decision of the Board of Tax Appeals overruling a determination of the Commissioner, assessing against the respondents a deficiency of $5,004.84 in income tax for the year 1931. The question is whether the owner of undivided interests in a participating trust, upon surrendering certificates representing such interests and receiving her proportionate share of the underlying securities of the trust is entitled to...
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