OPINION.
DAWSON, Judge:
Respondent determined a deficiency in income tax and an addition to tax under section 294(d) (1) (A) of the Internal Revenue Code of 1939 for the taxable year 1952 in the amounts of $9,250.50 and $825.41, respectively.
The only issue for decision is whether the petitioners received more than 30 percent of the sales price of their preferred and common stock in Radio Kentucky, Inc., in the taxable year 1952 so as to disqualify...
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