Memorandum Findings of Fact and Opinion
DISNEY, Judge:
The petition herein was filed for the purpose of redetermining deficiencies in income taxes for the calendar years 1939 and 1940, in the amounts of $302.41 and $2,166.47, respectively. Petitioners assign as error the Commissioner's action in adjusting their net income for each of the taxable years by increasing the amount of the long-term capital gain which they reported from the sale of preferred capital...
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