Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax as follows:
Year Deficiency Calendar year 1946 .................. $10,663.66 Period Jan. 1, 1947 to March 31, 1947 7,526.06 Fiscal year ended March 31, 1948 .... 36,038.75 Fiscal year ended March 31, 1949 .... 21,310.61
The principal issue is whether a transaction...
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