OPINION.
ARUNDELL, Judge:
Respondent determined a deficiency of $45,902.78 in income tax for the taxable year ended December 31, 1950. Two issues are involved: (1) Whether the respondent erred in determining that petitioner was taxable in 1950 on a short-term capital gain of $37,529.13 from some 51 "short sales" during the period from October 13, 1943, to January 20, 1949, inclusive, and (2) whether the respondent erred in determining that $50,295...
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