This proceeding involves deficiencies in income tax determined by the Commissioner for the years 1938 and 1939 in the respective amounts of $2,489.24 and $957.88. A minor portion of the deficiency is admitted by the petitioner. The sole question at issue is whether certain gains realized by the petitioner on transfers of shares of stock owned by him to the issuing corporation are taxable to him as distributions in partial liquidation, or as gains realized on sales of capital...
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