Memorandum Opinion
LEECH, Judge:
This controversy involves deficiencies in income tax of $100,402.51 and declared value excess-profits tax of $3,906.16 for the calendar year 1939. The primary issue is whether petitioner realized a taxable gain when it distributed certain of its assets to its two stockholders. If this issue is answered in the affirmative, a supplemental issue is whether, in computing the taxable gain, assets which had depreciated in value...
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