Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined a deficiency in income tax for the year 1948 in the amount of $590.14 against petitioner. The principal basis for the deficiency was that petitioner failed to report a capital gain upon the sale of certain property. It appears that such property belonged to petitioner's wife, and the Commissioner originally proposed to justify his position on the ground that petitioner...
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