Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $40,248.55 in petitioner's 1936 income tax, as a result of several adjustments. The petitioner assails the inclusion in his gross income of the value of 45,000 shares which is "explained" in the deficiency notice as follows:
It is held that the delivery to you during the taxable year 1936 of 45,000 shares of capital stock of Peerless Corporation pursuant to settlement of...
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