The respondent determined deficiencies in the income tax of petitioner in the amounts of $61,244.87 for the year 1946 and $64,215.93 for the year 1947.
The principal question is whether the petitioner realized taxable income in 1946 and 1947, when he exercised an option to purchase 12,500 shares of the common stock of the National Tea Company, which he had acquired in 1945.
FINDINGS OF FACT.
A stipulation of facts filed by the parties is adopted...
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