Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioners' income tax for the calendar year 1940, in the amount of $3,672.84. Petitioner concedes the correctness of certain minor adjustments, but challenges the correctness of the determination to the extent of $3,655.39 of the deficiency, on the ground that the disputed item of income constituted consideration for the sale of a capital asset, taxable to the extent provided by...
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