Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in petitioner's income tax for the calendar years 1940, 1941 and 1942 in the respective amounts of $2,980.78, $5,234.37 and $7,542.40, and in its declared value excess profits tax for 1942 in the amount of $423.44.
The deficiencies arose from respondent's denial of petitioner's right to use the substituted basis of its transferor corporation of certain real estate transferred...
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