DRENNEN, Judge:
Respondent determined a deficiency in petitioner's income tax for the taxable year 1960 in the amount of $124,021.02.
The issues for decision arise from a transaction in 1960 by which petitioner, Jack I. LeVant (hereafter referred to as petitioner or LeVant), exchanged an option to purchase a 20-percent interest in the business of S. M. Edison Chemical Co., Inc. (hereafter referred to as Edison, Inc.), for 6,494 shares of stock of Colgate...
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