Memorandum Opinion
OPPER, Judge:
Respondent determined a deficiency of $53,635.40 in the petitioner's income tax for the calendar year 1938, which petitioner by this proceeding challenges, claiming in addition an "overassessment" of $56,666.90. The issue is whether or not cash and securities received by petitioner upon the liquidation of a partnership of which he had been a member constitute taxable income, where petitioner had in previous tax years claimed...
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