Memorandum Findings of Fact and Opinion
The respondent determined a deficiency of $3,300.42 in the petitioner's income tax for the year 1942.
The sole issue is whether or not the sum of $12,058.31, representing the excess amount collected on bank deposits over the value thereof fixed in the estate tax return, constituted taxable income to the Estate of R. H. Pfaff.
Findings of Fact
The facts were stipulated substantially as follows:
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