James G. Smyth, Collector of Internal Revenue v. George G. Cole and Myrtle N. Cole

In substance and effect the trial court found that there was no basis in fact for ascribing any value to the growing oranges at the time the orchard was sold. This ought to be enough, unless we desire to have the court go through the idle ceremony of finding a nominal value. I would affirm for the reasons given in the opinion below, 96 F.Supp. 745.