MOORE, Circuit Judge:
This suit for a tax refund was submitted to the trial court for decision upon a joint stipulation of facts and uncontroverted facts in a pre-trial order. Pertinent to decision are the following:
Prior to his death, plaintiff's husband, Edmund T. Quick (the decedent) had contracted to sell 640 acres of land for $1,100,000 on an installment basis with the proviso that the seller would convey to the purchaser one acre for each $2,000 paid...
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