Memorandum Findings of Fact and Opinion
BRUCE, Judge:
This proceeding involves a deficiency in income tax of $49,928.05 asserted by respondent for the calendar year 1944. The issue is whether respondent erred in increasing petitioner's income for the taxable year by an amount determined by him to have been compensation for personal services and representing the difference between the market price and the option price paid by petitioner for the shares of...
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