The Commissioner has determined a deficiency in petitioner's income tax for the year 1955 of $14,442.30. The deficiency is due to one adjustment which the Commissioner has made to the net income reported by petitioner on its return for 1955. That adjustment was "(a) Capital Gains $58,633.70," and is explained in the deficiency notice as follows:
(a) Because the property was not converted into other property similar or related in service or use to the converted property...
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