TRAIN, Judge:
Respondent determined a deficiency of $82,224.86 in petitioners' income tax liability for 1958.
Some of the issues have been settled. The issue remaining for decision is whether stock and $64,850 received by Henry McK. Haserot from his controlled corporation in return for stock in two other controlled corporations are taxable as a dividend or are to be treated as payment for stock and taxed as long-term capital gain.
FINDINGS...
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