OPINION.
TIETJENS, Judge:
The respondent determined a deficiency of $11,731.30 in income tax for the calendar year 1952. The sole issue for decision is whether the petitioner is entitled to the benefits provided by section 112(b)(7) of the Internal Revenue Code of 1939 as to recognition of gain upon the liquidation of a corporation. The facts are found as stipulated. The petitioner's return for 1952 was filed...
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