MELLOTT, Judge:
The Commissioner determined a deficiency in the income tax of petitioner for the year 1939 in the amount of $13,207.72.
The sole issue is — what is the basis for gain or loss of 3,000 shares of common stock of the Investors Trust Company sold by petitioner in 1939? The answer depends upon whether the transaction whereby petitioner and others received shares of Investors Trust Company stock for stock of Investors Corporation was within...
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