Memorandum Findings of Fact and Opinion
HILL, Judge:
This proceeding involves an income tax deficiency of $21,808.12 for the year 1940. Petitioner, an individual, duly filed his income tax return with the collector of internal revenue for the third district of New York and reported as a long-term capital gain the result of his dealings in Canadian money. Respondent determined the deficiency by treating the amount reported as ordinary income. Petitioner now...
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