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HAYS CORPORATION v. COMMISSIONER

Docket No. 87979.

40 T.C. 436 (1963)

THE HAYS CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 28, 1963.

Attorney(s) appearing for the Case

James F. Thornburg and Edward J. Gray, for the petitioner.

George H. Becker, for the respondent.

OPINION

FORRESTER, Judge:

Respondent has determined a deficiency in income tax of petitioner for the taxable year 1957 in the amount of $12,185.68. Petitioner has agreed to certain adjustments, and the issue remaining is whether petitioner's basis in certain stock was its cost to petitioner or its basis in the hands of its former holders. Wholly dependent on the resolution of this issue is the determination of the amount of a net operating loss carryover...

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