This proceeding is for the redetermination of a deficiency in income tax for the calendar year 1940 in the amount of $9,921.49. The only issue is what, if any, capital gain petitioner realized on the transfer of certain common stock. Petitioner's return for 1940 was filed with the collector of internal revenue for the first district of Pennsylvania at Philadelphia.
The case was submitted upon a stipulation of facts, oral testimony, and exhibits introduced at the hearing...
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