Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The respondent has determined a deficiency of $12,113.89 in the petitioner's income tax for the year 1946. The issues presented are the correctness of the respondent's action in determining (1) that no part of the proceeds received by the petitioner from the sale of standing white oak timber and stave bolts was taxable as a long-term capital gain from the sale of good will, and (2) that no portion of...
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