Memorandum Opinion
RICE, Judge:
This proceeding involves a deficiency in income tax for the year 1949 in the amount of $2,397.07.
The only issue is whether the gain realized by petitioner from the repayment of a debt owed in British pounds sterling, incurred in its trade or business, with devalued pounds sterling is taxable as ordinary income or as a short-term capital gain.
All of the facts were stipulated, are so found, and are incorporated...
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