Memorandum Findings of Fact and Opinion
SMITH, J.:
The Commissioner has determined a deficiency of $13,171.43 in the income tax of Morgan J. Hammers, deceased, for 1936. The deficiency results in principal part from the Commissioner's determination that the decedent realized a taxable gain in 1936 from the receipt of shares of stock which he acquired upon organization of the issuing company following a bankruptcy proceeding under section 77-B of the Bankruptcy...
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