Memorandum Findings of Fact and Opinion
This case comes before us on respondent's determination of a deficiency in petitioner's income tax for the year 1937 of $16,534.58. The issue is whether petitioner realized gain from the sale in the taxable year of stock which had been acquired by himself and two others in fixed proportions for the purpose of resale, but only part of which was determined to have been sold, the balance being distributed to the three adventurers...
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