Memorandum Findings of Fact and Opinion
The respondent determined a deficiency in income tax against the petitioner for the year 1939 in the sum of $152.63. The sole issue raised by the pleadings is whether or not the petitioner realized a taxable profit during the taxable year as a result of repayment of a mortgage indebtedness by the transfer of stock having a cost basis to the petitioner of less than the amount of the indebtedness discharged.
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