Memorandum Opinion
MURDOCK, Judge:
The Commissioner determined a deficiency of $13.01 in income tax for 1941. The only issue for decision is whether $3,900 received by the petitioner in 1941 is taxable as ordinary income or as capital gain. The facts have been stipulated.
The petitioner filed her separate individual income tax return for 1941 with the collector of internal revenue for the district of South Carolina. She reported $3,900 as income...
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