Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
Respondent determined a deficiency in income tax for the year 1948 in the amount of $1,537.08, and a penalty of $384.27 for failure to file a return within the time prescribed by law.
The following issues are presented:
(1) Is petitioner's gain from an involuntary conversion recognized in 1948 under section 112 (f), I. R. C.?
(2) Is petitioner liable for the penalty imposed by...
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