The Commissioner determined a deficiency in petitioner's income tax for the fiscal year ended June 30, 1960, in the amount of $50,911.97.
The sole issue is whether the substance of a certain transaction was a taxable sale or exchange by the taxpayer of its interest in certain land or whether the realized gain in respect thereof is to escape taxation under section 354(a)(1) of the 1954 Code through the use of an intermediate corporation to which such property was first...
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