BOWEN, District Judge.
In this case a trustee was appointed by the corporate taxpayer to liquidate and distribute its assets. In aid of liquidation and distribution the trustee by two separate sales sold all of the physical non-cash assets of the corporate taxpayer to its majority stockholder at a loss to the corporate taxpayer. Later the proceeds of such sales were distributed to that majority stockholder and the other stockholders, and the majority stockholder also...
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