Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined deficiencies in income taxes of petitioner for the taxable year 1954 in the amount of $3,169.62, and for the taxable year 1955 in the amount of $9,820.11. The issues for decision are:
(1) Whether the fair market value of property received by petitioner as a liquidating dividend was in excess of $37,793.10; and
(2) Whether reasonable allowances for depreciation and...
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