Memorandum Findings of Fact and Opinion
MELLOTT, Judge:
The Commissioner determined a deficiency in petitioner's income tax for the year 1936 in the amount of $457.71. Petitioner concedes that he erroneously failed to include in his gross income any part of the gain realized by him in the disposition of 1,530 shares of stock. He contends, however, that only a portion of the gain should be included in computing his taxable income since it resulted from the...
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