Memorandum Findings of Fact and Opinion
HILL, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1943 in the amount of $1,609.34. The adjustments reflected in the deficiency notice giving rise to the deficiency are not here in controversy. Petitioner here claims that certain payments received by him during 1942 and 1943 from Remington Rand, Inc., constituted proceeds from the sale of capital assets held by him more...
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