Memorandum Findings of Fact and Opinion
RAUM, Judge:
The Commissioner determined a deficiency in the income tax of petitioner Wide Acres Rest Home Inc. for the taxable year 1963 in the amount of $4,768.50. The only question is whether petitioner was required to include in income in the taxable year of receipt the entire fair market value of stock received in that year in consideration for the lifetime care of an elderly patient at its rest home, or whether...
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