For the year 1951 the respondent determined a deficiency in income tax against the petitioners in the amount of $10,715.94, and, under section 294(d)(2) of the Internal Revenue Code of 1939, an addition to tax in the amount of $824.41 for substantial underestimation of tax. The questions raised are (1) whether petitioner Joseph Simon realized income upon the transfer of property owned by him to a corporation in which he was the owner of 50 per cent of the common stock, where...
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