CROCKER, District Judge.
This matter came on for hearing on the Petition of the District Director of Internal Revenue for Review of the Referee's Order of February 12, 1963, Herbert D. Sturman, Assistant United States Attorney, appearing for Petitioner; Robert L. Williams, Esq., appearing for the Respondent Trustee; and the matter was submitted to the court for decision on the basis of the record, briefs and oral argument of counsel.
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