This proceeding involves deficiencies for the years 1946 and 1947 in amounts of $1,967.95 and $36,656.04, respectively. The case has been submitted on stipulated facts. The deficiency for 1946 arises over differences between the Commissioner and the petitioner concerning the appropriate adjusted basis on which to determine the long-term capital gain on securities sold in 1946. This matter has been settled by the parties. The deficiency for 1947 arises over differences between...
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