Memorandum Findings of Fact and Opinion
OPPER, Judge:
Respondent determined deficiencies in income tax for the years 1955, 1956, and 1957 in the respective amounts of $3,388.28, $2,596.08, and $2,797.54, which are contested by petitioners Rebecca Silverman and the Estate of Herman Silverman, who is hereinafter referred to as decedent. The sole issue is whether amounts distributed to decedent by a corporation of which he was majority stockholder in exchange...
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