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HALL v. COMMISSIONER

Docket No. 21027.

15 T.C. 195 (1950)

FRED C. HALL, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated August 31, 1950.

Attorney(s) appearing for the Case

Eli Freed, Esq., for the petitioner.

T. M. Mather, Esq., for the respondent.

The Commissioner determined deficiencies in the petitioner's income and victory tax liability for the year 1943 in the amount of $614.96, and a deficiency in petitioner's income tax liability for the year 1944 in the amount of $952.67. The year 1942 is also involved because of the provisions of the Current Tax Payment Act.

The issue in this proceeding is whether the fair market value of 50 shares of stock issued in petitioner's name in 1942 is includible in his gross...

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