Memorandum Opinion
LEECH, Judge:
This proceeding involves a deficiency in income tax for the calendar year 1941 in the amount of $5,550.57, only a part of which is in controversy. The contested issue is whether petitioner sustained a deductible loss on the sale of his shares of the capital stock of Tavannes of America, Inc., to that corporation in view of the provisions of section 24 (b) (1) (B) of the
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