Respondent determined a deficiency in petitioner's income tax for the calendar year 1939 in the sum of $33,630.63. The issue presented in this proceeding is whether profits received by petitioner on the liquidation of a corporation should be treated as a short term capital gain realized in a partial liquidation, or as a long term capital gain realized in a complete liquidation.
The facts herein have been stipulated by the parties.
FINDINGS OF FACT.
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