Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in petitioners' income tax of $3,358.94 and $177,096.56 for the years 1951 and 1952, respectively.
The issues to be decided are:
1. Whether $11,225 received by petitioners in 1951 from the sale of certain stock constituted a short-term capital gain or ordinary income.
2. Whether petitioners received stock in July 1951, which they exchanged for...
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