OPINION.
RAUM, Judge:
Petitioners, husband and wife, filed a joint income tax return for the calendar year 1950 with the collector of internal revenue for the district of New Jersey. The Commissioner determined a deficiency in the amount of $39,051.42, based upon four adjustments, three of which are not contested. The fourth treated a gain of $68,906.38 that was realized upon the sale of stock in three corporations as ordinary income under section...
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