Memorandum Findings of Fact and Opinion
This proceeding involves Federal income taxes for the years 1948 and 1949 in the aggregate amount of $38,304.21.
In an opinion promulgated September 28, 1956, this Court, on the facts then before us, held that petitioner was not entitled to capital gains treatment under section 117 (k)(2) of the Internal Revenue Code of 1939
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