The Commissioner determined a deficiency of $10,420.36 in income tax for 1940. The petitioner assails the determination (1) that a transaction in shares was an exchange, and assails (2) the Commissioner's valuation of the shares received.
Findings of Fact
The petitioner, a resident of the City of New York, filed his 1940 income tax return in the Third District of New York.
1. Prior to 1940, the petitioner, at a cost of $44,000 acquired 1,875 preferred...
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