Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies in petitioner's income tax for the years 1955 and 1956 in the amount of $16,815.13 and $17,000, respectively. The deficiencies, insofar as the issue here presented is involved, are alternative and respondent concedes that if his position is sustained as to either year, it should not be sustained as to the other.
The issue for decision is whether petitioner realized...
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