Memorandum Findings of Fact and Opinion
Respondent determined a deficiency of $4,541.16 in petitioner's income tax for the year 1963. The only issue for our consideration is whether the gain realized by petitioner on the sale on July 9, 1963 of shares of Northwestern National Life Insurance Company common stock is taxable as ordinary income as gain from the sale of "property held by the taxpayer primarily for sale to customers in the ordinary course of his trade...
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