Memorandum Findings of Fact and Opinion
Respondent determined a deficiency in the Federal income tax of petitioners for the year 1950 in the amount of $18,837.37. The greater part of that deficiency and the only part here in issue results from respondent's determination that the fair market value of an apartment hotel received by petitioner Albert in the liquidation of a corporation wholly owned by him was $1,024,500. This property was sold by Albert during the...
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