Memorandum Findings of Fact and Opinion
HARRON, Judge:
Respondent determined deficiencies in income tax for the year 1938 as follows: F. W. Leadbetter, docket No. 110258, $14,849.98; Caroline P. Leadbetter, docket No. 110259, $21,540.06. The deficiencies are contested in part. The questions in issue are:
(1) Whether petitioners realized taxable income upon the transfer of certain stock by F. W. Leadbetter in exchange for securities owned by the Pittock...
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