Memorandum Findings of Fact and Opinion
Respondent has determined a deficiency in the income tax of petitioners for the calendar year 1949 in the amount of $721,053.10. The sole issue for determination is whether the sum of $1,308,450 received by one of the petitioners in 1949 constituted the price paid for shares of stock in a corporation, as contended by petitioners, or consideration paid for the release of an employment contract, as determined by respondent....
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