Memorandum Findings of Fact and Opinion
DAWSON, Judge:
Respondent determined a deficiency in the income tax of petitioners for the year 1960 in the amount of $9,740.80.
At issue is whether a donation by petitioners of capital stock in their controlled corporation to a charitable foundation followed shortly thereafter by the corporation's redemption of the stock and the use of the proceeds of the redemption by the foundation to satisfy a personal...
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