The Commissioner determined a deficiency of $4,762.56 in the petitioner's income tax for the year 1946. The deficiency results from the determination by the Commissioner that the entire amount of a long-term capital gain of $51,806.84, realized by the petitioner on the involuntary conversion in 1946 of 50.2 acres of farm land, with improvements including the petitioner's residence must be recognized under section 112 (f) of the Internal Revenue Code in computing petitioner...
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