Memorandum Findings of Fact and Opinion
The Commissioner has determined deficiencies of $25,042.96 in income tax for the taxable year 1939 and $17,912.91 in income and defense tax for 1940.
In his determination for the taxable year 1939 the Commissioner included the sum of $56,793.90 as the fair market value of 1990 shares of stock received by petitioner in that year. At the hearing it was agreed and stipulated by the parties that the fair market value of...
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