Memorandum Findings of Fact and Opinion
WITHEY, Judge:
The Commissioner determined a deficiency in the income tax of petitioner for the taxable year 1954 in the amount of $2,890.30. Petitioner claims an overpayment in her income tax for the year 1954 in the amount of $2,012.87.
The issue for determination is whether the fair market value of an undivided one-half interest in certain real property received by petitioner as a liquidating dividend on...
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