OPINION.
STERNHAGEN, Judge:
The Commissioner determined a deficiency of $14,698.31 in petitioner's income tax for the fiscal year ending October 31, 1939. Admitting $1,399.41 of the deficiency to be correct, petitioner contests the remainder, which results from a determination of the basis for computing gain or loss in an exchange. The facts are stipulated and are found as stipulated.
The petitioner...
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