Memorandum Findings of Fact and Opinion
The Commissioner determined income tax deficiencies for the taxable years 1951, 1952, and 1953 in the respective amounts of $22,309.36, $4,830.95, and $7,676.72.
The chief issue is whether a transfer by petitioner in 1951 of all of the assets of its hardware business in exchange for 8,000 shares of petitioner's stock was a sale for stock, or a distribution in partial liquidation under section 115(c), 1939 Code, in...
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