Memorandum Findings of Fact and Opinion
OPPER, Judge:
A deficiency in income tax for 1955 of $60,623.47 is in controversy. The question is whether an interest in a contract of sale distributed to petitioner as a result of a corporate liquidation had an ascertainable fair market value at that time. This is the only controversy, the parties having agreed that respondent's method of computing the value was correct...
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