Memorandum Findings of Fact and Opinion
SMITH, Judge:
This is a proceeding for the redetermination of a deficiency in income and declared value excess profits tax for the calendar year 1940 in the amounts of $1,399.89 and $580.67. The sole issue is whether the petitioner realized taxable income of $12,177.02 by reason of its acquisition of mortgage certificates against its property and its application of those certificates in reduction of its mortgage debt...
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