The respondent determined deficiencies in the income tax of Herbert B. Miller for 1946 and 1947 in the amounts of $1,882.27 and $3,982.35, respectively. The issues are, first, whether certain corporate distributions constituted taxable dividends, and, second, whether the purported sale of various assets to a corporation together with a contribution of cash constituted in reality a transfer governed by the nonrecognition provisions of section 112 (b) (5) and the basis provisions...
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