OPINION.
RICE, Judge:
Respondent determined deficiencies in income and excess profits taxes for the taxable year ended October 31, 1946, in the respective amounts of $1,820.91 and $3,361.68. The only issue is whether the sum of $22,500 received by petitioner from Jamlee Hotel Corporation was taxable as ordinary income or as capital gain.
The facts were stipulated. The stipulated facts are so found and are incorporated herein by reference....
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