This proceeding involves an asserted income tax deficiency of $4,183.56 and a claimed overpayment of $4,640 for the calendar year 1947.
The petitioner assigns as errors: (1) the respondent's action in including in ordinary income the amount of $13,500 reported on the return as a capital gain realized on the cancellation of a certain contract in December 1947, and (2) the petitioner's action in reporting on his 1947 return as ordinary income instead of a capital gain...
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