Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency in the income tax of petitioners for the year 1954 in the amount of $233,075.96. The issues for decisions are: (1) Whether certain shares of stock of the C. H. D. Corporation had a fair market value of $285,000 when petitioner James H. Knowles purchased them on September 23, 1954, from the majority stockholders of C. H. D. Corporation for...
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