Memorandum Findings of Fact and Opinion
ATKINS, Judge:
The respondent determined deficiencies in income tax of the petitioner and its subsidiary company for the taxable years 1946 and 1947 in the respective amounts of $27,190.01 and $31,465.83.
Some of the issues raised by the pleadings have been conceded by the petitioner. The issues remaining for decision are (1) whether the transfer in 1946 by petitioner of 1,000 shares of stock of The William...
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