SCOTT, Judge:
Respondent determined deficiencies in petitioners' income taxes for the taxable years 1955 and 1957 in the amounts of $31,478.78 and $2,926.31, respectively.
The issue for decision is whether the amounts of $41,600 in 1955 and $4,144.25 in 1957 which represented the difference between the fair market value at the date of transfer of common stock received by petitioner Dorothy L. Johnson in discharge of advances made to an estate of which...
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