Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent has determined deficiencies in income tax for the years 1940 and 1941 in the respective amounts of $26,268.46 and $164,925.28. The first question is whether the wife and children of petitioner were stockholders in a corporation. Respondent has determined that they were not, and that the entire capital gain realized upon the liquidation of a corporation, Wilkoff Company, is taxable to petitioner...
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