Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax for the calendar years 1949 and 1950 in the respective amounts of $4,093.50 and $6,572.48.
The principal question is whether amounts received by the petitioner Sam Gold, constituted proceeds from the sale of his stock in a wholly-owned corporation and, therefore, capital gains, or whether they constituted ordinary income. Also involved is the...
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