The Commissioner has determined a deficiency in petitioner's income tax for the year 1945 of $1,558.71. The deficiency is due to an adjustment which is explained in the deficiency notice, as follows:
(a) It is held that you realized taxable income in the amount of $5,972.84 from the exchange during the calendar year 1945 of your twenty-five percent partnership interest in Arcadia Roller Rink for six percent notes of Leo O. Seltzer having a face value, and a fair market...
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