PIERCE, Judge:
Respondent determined a deficiency in income tax against petitioners in the amount of $5,970.45 for the taxable year 1959.
The issues for decision are:
(1) Whether the principal petitioner's purported transfers to his two children of 50 percent of his stock in a wholly owned business corporation, which he then elected to have taxed as a subchapter S corporation under sections 1371-1377 of the 1954 Code, were bona fide and economically...
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