OPINION.
TIETJENS, Judge:
The Commissioner determined a deficiency of $13,808.75 in income tax for 1947. By amended answer the Commissioner has requested an increased deficiency resulting from adding to the petitioner's reported income, long-term capital gain of $29,034.59 rather than $27,500 as set out in the deficiency notice.
In his original determination the Commissioner added rental receipts of $99.75 to the petitioner's income for 1947...
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