The respondent has determined a deficiency of $8,118.88 in the petitioners' income tax liability for the taxable year ended December 31, 1946. The petitioners contest the entire deficiency and allege as error the respondent's inclusion in 1946 taxable income of the difference between the option price at which the petitioners acquired shares of stock and their market value at the time the option was exercised and the stock was acquired. The respondent's disallowance of part...
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