Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This proceeding involves deficiencies of $24,870.32 and $4,345.40 in income tax for the respective years 1940 and 1941. The issues still in controversy are the gain realized by petitioner in 1940 upon the disposition of part of his interest in the Joe Long Drilling Co.; whether such gain is taxable as capital gain, and whether an oil payment received in 1941 in the amount of $34,524.87 is separate income...
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