Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioner's income tax for the calendar year 1941 in the sum of $130,654.27. That part of the deficiency which is here in issue resulted from the Commissioner's determination that petitioner realized ordinary income, rather than capital gain, when he transferred to a corporation of which he was president and majority stockholder 235 shares of his stock therein and received $52,847...
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