The Commissioner has determined a deficiency in income tax for the year 1946 in the amount of $33,820.30. The petitioner contests the entire deficiency and claims overpayment of tax in the amount of $4,345.95. He was a citizen and resident of Sweden during and before the taxable year.
The deficiency results principally from the inclusion in the petitioner's gross income of a long-term capital gain in the amount of $152,555.87, realized upon the sale of real property...
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