Memorandum Findings of Fact and Opinion
HARRON, Judge:
The Commissioner determined an income tax deficiency for the taxable year 1955 in the amount of $261,878.01. The deficiency results from the determination of the respondent that the petitioner, Bruce Berckmans, realized income in the amount of $311,669.50, upon the acquisition in 1955 of 36,667 shares of new capital stock of a corporation, under section 61 of the 1954 Code. The question is whether upon...
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