Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
The respondent determined a deficiency in petitioner's income tax for the taxable year ended October 31, 1958 in the amount of $7,337.69. The issues are (1) whether gain realized by petitioner from the sale of certain property is non-recognized gain within the provisions of section 337 of the Internal Revenue Code of 1954;
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