The Commissioner determined a deficiency of $28,871.75 in income tax of the petitioner for the period May 24-July 31, 1943, and a deficiency of $35,253.34 for the fiscal year ended July 31, 1944, in part by recomputing gains on the sales of mills which were contributed to it as paid-in surplus by its shareholders. Undivided interests in these mills had been distributed as a liquidating dividend to the shareholders immediately prior to their transfer to petitioner by a corporation...
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