Memorandum Findings of Fact and Opinion
WITHEY, Judge:
Deficiencies in income tax for the years 1950 and 1951 have been determined by the Commissioner against petitioner Mutual Finance Company, a corporation, in the amounts of $4,373.71 and $3,129.86, respectively. The sole issue for determination is whether the excess of insurance premiums received by petitioner over the cost to it of the right to receive those premiums constitutes capital gains or ordinary...
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