Memorandum Findings of Fact and Opinion
The Commissioner determined deficiencies in petitioner's income tax of $10,401.90 for 1937, $18,640.72 for 1938, and $18,248.90 for 1939, by treating as dividends, and thus ordinary income amounts which petitioner treated as capital gains.
Findings of Fact
Petitioner is a resident of Rochester, New York. He prepared his income tax returns for 1937, 1938 and 1939 on the basis of cash receipts and disbursements...
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