Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in petitioner's income tax for the years 1938 and 1939 in the respective amounts of $2,115.32 and $37,171.35. The entire deficiencies are contested.
The single issue presented is whether the respondent erred in treating the respective redemptions in 1938 and 1939 of 42 and 200 shares of stock held by the petitioner, as redemptions essentially equivalent to distributions of taxable...
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