Memorandum Findings of Fact and Opinion
HARRON, Judge:
Respondent determined a deficiency in income tax for the year 1941 in the amount of $84,387.65. The deficiency is due to respondent's determination that petitioner received amounts under a distribution by a corporation in complete cancellation of part of its stock, and that, therefore, the distribution was made in partial liquidation of the corporation. Accordingly, respondent has included 100 percent...
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