Memorandum Findings of Fact and Opinion
ARUNDELL, Judge:
This proceeding involves a deficiency of $10,274.71 in income tax for the calendar year 1941.
Four issues are raised:
(1) Was the short-term capital gain on the sale of the steamer, Belgium, the income of petitioner or was the amount in question properly reportable as income of his sons?
(2) Did the respondent err in disallowing...
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