Memorandum Findings of Fact and Opinion
HARLAN, Judge:
The Commissioner determined a deficiency of $26,113.12 in the income tax of petitioner for the calendar year 1944. The deficiency resulted from a reduction by the Commissioner in the basis returned by petitioner for computation of capital gain on the sale in 1944 of an undivided one-half interest in fee in certain improved real property located at 554-562 Main Street, Buffalo, New York. The parties agree...
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