Memorandum Opinion
MELLOTT, Judge:
The Commissioner made two adjustments to the net income shown by petitioner's return for the calendar year 1940 and determined a deficiency in income tax in the amount of $1,792.36. The sole charge of error is predicated upon the addition of $15,000 as "Payment for Services." This amount represents the value of 200 shares of Toner's Inc. stock, transferred to petitioner immediately after its organization under the circumstances...
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