OPINION.
KERN, Judge:
On August 28, 1953, respondent filed a motion for judgment on the pleadings on the ground that the facts stated in the petition are insufficient at law to establish petitioner's right to relief under Internal Revenue Code section 722. The motion for judgment was accompanied by a memorandum of authorities, hearing was duly had upon the motion, and the respective parties have submitted their briefs.
An amended petition...
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