Memorandum Findings of Fact and Opinion
OPPER, Judge:
This proceeding is before us on mandate from the Court of Appeals for the Second Circuit [54-1 USTC ¶ 9151]. The case was first considered by us, after hearing, and a report was promulgated on June 12, 1952 [Dec. 19,029]. The issues then presented were (1) whether the provisions of section 107 of the Internal Revenue Code were available to petitioner in the computation of his tax for 1945, and (2...
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