Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $19,214.67 in the petitioner's income tax for the fiscal year ending February 28, 1953. The primary issue for decision is whether $45,941.60 received from the assignment of oil and gas leases, $45,426.10 of which was distributed to its shareholders in 1952, should be taxed as income to the petitioner.
Findings of Fact
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