ARUNDELL, Judge:
The respondent has determined a deficiency in the amount of $35,853.24 in the income tax of the petitioners for the taxable year 1946. The issues to be decided are as follows:
1. Whether 172 issues of stock from a block of 186 issues purchased in the name of J. M. Kaplan, hereinafter referred to as petitioner, were bought by him and later sold to Navajo Corporation, hereinafter sometimes referred to as Navajo, or whether the purchased...
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