Memorandum Opinion
SMITH, Judge:
The respondent has determined a deficiency of $6,815.04 in petitioner's income tax for the fiscal year ended June 30, 1940. The questions in issue are whether petitioner sustained a deductible loss or realized a taxable gain in 1940 upon the assignment to its principal stockholder and former president of certain policies of insurance on his life; and whether, if a loss, it was an ordinary loss or a capital loss.
The...
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