Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This proceeding involves an income tax deficiency in the amount of $6,764.24 for the year 1941. The contested issue is whether the sum of $25,164.69 received by petitioner Colin J. MacLeod in 1941 was taxable as ordinary income as held by respondent or as a long-term capital gain represented by the sale of a partnership interest as contended by petitioner.
The case was submitted on a stipulation...
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