Memorandum Findings of Fact and Opinion
DISNEY, Judge:
This proceeding involves a deficiency of $26,175.42 in income tax for the year 1943. The issue is whether the respondent erred in determining that ordinary income of $47,625, instead of capital gain, was received by petitioner in a certain settlement agreement. The facts set forth in a stipulation are found as therein agreed upon. Portions thereof, which we consider necessary for proper consideration...
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