OPINION.
MELLOTT, Judge.
The Commissioner determined a deficiency in the income tax of petitioner for the calendar year 1939 in the amount of $78.72. Petitioner claims she has made an overpayment of tax in the amount of $750.80.
The sole question is whether liquidating distributions received by petitioner in 1938 and 1939 were "amounts distributed in complete liquidation" within the meaning of section 115 (c) of the Internal Revenue Code....
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