FAY, Judge:
Respondent determined deficiencies in the petitioner's income tax for the calendar years 1955 and 1956 in the amounts of $120,088.61 and $1,635.59, respectively. The petitioner concedes the correctness of several of the respondent's adjustments for 1955 and all of the respondent's adjustments for 1956. The only issue remaining for decision is whether section 357(c) of the Internal Revenue Code of 1954 applies when the only liabilities assumed by...
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