Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
Respondent has determined a deficiency in petitioner's income tax for the year 1960 in the amount of $778.47 and an addition thereto under section 6653(a) of the Internal Revenue Code of 1954 in the amount of $45.36. The primary issue is whether petitioner's receipt of a check in the amount of $3,235.43 in January 1960 represented additional unreported income taxable as long-term capital gain. The...
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