OPINION.
RAUM, Judge:
The petitioner contests a determination of deficiency in income tax for the year 1949 in the amount of $190,147.49. The only question is whether the amount of $500,000 received in 1949 by Pattison & Bowns, Inc., a wholly owned subsidiary of petitioner, from the Russell Fork Coal Company, is taxable as capital gain or ordinary income. All of the facts have been stipulated.
On January 25, 1944, Pattison & Bowns...
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