v2888-1233

7

POINTS ON APPEAL

Appellants' Statement of Points on Appeal is set

forth on pages 103, 104 and 105 of the Transcript

of the Record and are adopted as a part of this brief.

SPECIFICATION OF ERRORS

Appellants make the following specification of

errors relied upon in this appeal:

The Tax Court of the United States erred in

finding as a fact that Periodical Estimate No. 6 (Pe-

titioners' Ex. 7 below) was certified to in 1942, and

such finding is contrary to the evidence.

The Tax Court of the United States erred in find-

ing as a fact that there was no substantial contin-

gency as to the right of Appellants to receive on De-

cember 31, 1942, the sum of 90 per cent of $136,-

528.34 paid Appellants pursuant to Periodical Esti-

mate No. 6 (Petitioners' Ex. 7 below) and such find-

ing is contrary to the evidence.

III.

The Tax Court of the United States erred in

finding as a fact that as of December 31, 1942, the

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