Memorandum Opinion
HARRON, Judge:
The respondent has determined a deficiency in petitioner's income tax for the year 1940 in the amount of $11,567.91. The question for determination is the amount of gain realized by petitioner in a transaction under which he surrendered to GM Shares, Inc., a Delaware corporation, 400 shares of its class A stock and received in exchange therefor 400 shares of the common stock of General Motors Corporation. The respondent...
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