Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined a deficiency of $4,949.99 in petitioner's income tax liability for the calendar year 1947. The sole issue presented is whether the respondent erred in determining that the fair market value of a purchaser's secured promissory note and of the petitioner's proportionate interest therein was equal to the face amount thereof, namely, $300,000 for the note and $59,400 for petitioner...
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