Supplemental Memorandum Findings of Fact and Opinion
This proceeding is before us on remand from the United States Court of Appeals for the Ninth Circuit for further proceedings in accordance with the opinion of that court, appearing at 207 Fed. (2d) 265 (1953) [53-2 USTC ¶ 9563], certiorari denied 347 U.S. 942 (1954). In that opinion, the court reversed our prior holdings in this proceeding, which appear at
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