Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined deficiencies in income tax of petitioner of $5,267.39 for the taxable year March 1, 1946 to December 31, 1946, and $18,127.57 for the calendar year 1947.
The only question for decision is whether the transfer of property to petitioner in exchange for stock of petitioner was a nontaxable exchange under section 112(b)(5) of the Internal Revenue Code so that the basis...
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