This case involves a deficiency in income tax for the year 1944 in the amount of $38,186.25. The issue to be decided is whether certain shares of stock, which were sold by the petitioner in 1944, were a gift to petitioner or whether they had been received by him for adequate consideration. If they were not a gift, a further issue is presented with respect to the basis of the stock for computing gain or loss thereon.
Some of the facts were stipulated.
FINDINGS...
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