OPINION.
DRENNEN, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1955 in the amount of $45,457.36. The issues for decision are: (1) Whether gain from the involuntary sale of all of petitioner's assets is includible in "income" for the purpose of applying the limitation in section 501(c)(12), I.R.C. 1954, under which petitioner was otherwise qualified for exemption from taxation; and (2) if petitioner was...
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