The Commissioner determined a deficiency in income tax for the taxable year 1946 in the amount of $12,599.04. The sole issue with which we are concerned is whether the basis of real property involved in this proceeding is $80,500 as determined in the deficiency notice, or $138,276.23 as contended by petitioner. Some of the facts were stipulated.
FINDINGS OF FACT.
The stipulated facts are so found and are incorporated herein.
Petitioner is a Delaware...
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