Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner has determined a deficiency in income tax against petitioner, Junior Amusement Co., for the taxable year 1949 in the amount of $19,106.75. By its pleading, petitioner asserts an overpayment of income tax for the same year in the amount of $8,665.58. The sole issue for our decision is the fair market value of the capital stock of Yakima Community Hotel, Inc., received by petitioner in...
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