Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined a deficiency in income tax for the taxable year 1959 in the amount of $27,895.29. The issues for decision are (1) whether some part of $350,000 received in 1959 by petitioner on behalf of himself and other members of the Scull group in a transaction purporting to be a sale of stock and securities of Penndale, Inc. in reality constituted consideration paid to the petitioner for...
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