OPINION.
ARUNDELL, Judge:
Respondent determined a deficiency in income tax for the taxable year ended January 31, 1952, in the amount of $1,694.46.
The only issue is whether an amount of $7,857.46 received by petitioner in the taxable year ended January 31, 1952, is taxable as long-term capital gain, as contended for by petitioner, or as ordinary income, as determined by respondent.
All of the facts were stipulated and are summarized...
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