Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in petitioner's income tax for the calendar year 1939 of $21,366.86, stating as the basis thereof, that "It has been determined that there was a realization of taxable income in the year 1939 when the securities pledged by the taxpayer as security for his note dated June 1, 1928 to Famous Lasky Corporation were returned to the taxpayer."
Findings of Fact
The petitioner is...
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