OPINION
ATKINS, Judge:
The respondent determined a deficiency in income tax for the taxable year 1961 in the amount of $6,427.35.
The issues presented are: (1) Whether the respondent's allocation of the basis computed under section 334(c) of the Internal Revenue Code of 1954 among the various assets (including notes and accounts receivable and a claim for income tax refund) received by the petitioner in liquidation of a corporation in proportion...
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