This proceeding involves a deficiency in income tax determined against Harold E. MacDonald and Marian B. MacDonald in the amount of $116,438.30 for the taxable year 1949.
The sole issue to be decided is whether petitioner Harold E. MacDonald realized additional income in the amount of $168,000 when he exercised an option to purchase stock from his employer-corporation for less than the market value of such stock.
Some of the facts were stipulated.
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