OPINION.
WITHEY, Judge:
Respondent determined a deficiency in the petitioners' income tax for 1952 in the amount of $60,495.57. The issue presented for our decision is the correctness of the respondent's action in determining that gain realized from the cancellation of stock options during 1952 constituted compensation for the services of petitioner Robert C. Enos and was therefore taxable to him as ordinary income.
The case was submitted...
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