Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined deficiencies in income tax against the petitioner for the taxable years 1952 and 1953 in the respective amounts of $264.60 and $459.04.
The only issue for determination is whether the respondent has erred in treating certain payments to the petitioner of part of the profits of a corporation by which he was employed and to which he had sold his stock as ordinary...
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