Memorandum Findings of Fact and Opinion
ARNOLD, Judge:
This case involves an income tax deficiency for the year 1940 in the amount of $5,765.92 as determined by respondent. The sole question is whether the sum of $22,750 received by the petitioner in January, 1940 from Mountain City Knitting Mills, a corporation, in exchange for 91 shares of stock in that corporation owned by
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