Memorandum Findings of Fact and Opinion
SMITH, Judge:
This proceeding is for the redetermination of a deficiency of $31,424.53 in petitioner's income tax for 1940. The questions in issue are whether the petitioner realized taxable income in 1940 when he surrendered bonds which he had purchased at a discount and acquired title to certain real estate which had been held by the trustee bank as security on the bonds; whether the gain, if any, is taxable in part...
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