Memorandum Findings of Fact and Opinion
FORRESTER, Judge:
The respondent determined a deficiency in the Federal income tax of the petitioner for the year 1955 in the amount of $134,027.54. The petitioner has not put in issue some of the adjustments made by the statutory notice, and the amount of the deficiency now in dispute is $128,265.77.
The sole issue for our decision is whether the Stahl Development Corporation was formed or availed of principally...
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