Memorandum Opinion
WITHEY, Judge:
The respondent has determined a deficiency in the petitioner's income tax for 1953 in the amount of $40,366.22.
The sole issue presented for our decision is the correctness of the respondent's action in determining the basis to be used in computing the amount of gain realized by petitioner through the involuntary conversion of its boats which were destroyed by a fire in 1953.
An additional issue presented...
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