Memorandum Opinion
LEMIRE, Judge:
This proceeding involves a deficiency in the income tax of petitioner for the taxable year 1953 in the amount of $1,427.10.
The sole issue is whether the transaction in 1953, whereby its stockholder-creditor on payment by petitioner of the principal of its note cancelled the accrued interest thereon, constituted a gratuitous forgiveness of indebtedness.
All the facts have been stipulated and are incorporated...
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