Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1960 in the amount of $108,636.58.
The issues for decision are:
(1) Whether petitioner Roy N. Livingston sustained a capital loss when all of the assets, subject to all of the liabilities, of a corporation of which he was the sole stockholder were transferred to him upon his surrender, for cancellation...
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