Memorandum Findings of Fact and Opinion
The respondent determined deficiencies of $750.46 and $3,397.35 in the petitioner's income taxes for the years 1936 and 1937, respectively.
The issues are:
1. The taxability in 1936 of the sum of $233.25, termed rental or interest, due on land trust certificates issued by the Paden City Pottery Company and represented by a check payable to the petitioner and, by
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