SCOTT, Judge:
Respondent determined a deficiency of $205,850.70 in income tax of the petitioner for the calendar year 1955. The issues for decision are whether the amount of $1,500,000 received by petitioner from its wholly owned Canadian subsidiary was an ordinary dividend as petitioner contends or a distribution in partial liquidation as determined by respondent; if the amount was a liquidating distribution, whether petitioner in accordance with its alternative...
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