Memorandum Findings of Fact and Opinion
HILL, Judge:
This proceeding involves an income tax deficiency of $57,894.28 and an excess profits tax deficiency of $45,639.81 for the year 1938. The sole question is the amount of gain realized by petitioner on the sale of its oil properties to the Shell Oil Company in 1938. The petitioner filed an income and excess profits tax return for the year 1938 with the collector of internal revenue for the sixth collection...
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