Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in income tax of $27,470.98 for 1944 and one of $60,105.46 for 1945. The only issue for decision is whether there was a business purpose for a reorganization in 1944 so that the petitioner acquired the basis of another corporation for property sold in the taxable years.
Findings of Fact
The petitioner was incorporated in 1912 and dissolved in 1949, but its existence...
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