Memorandum Findings of Fact and Opinion
MULRONEY, Judge:
Respondent determined a deficiency in petitioner's income tax for 1956 in the amount of $280,386.81. The issues are: (1) Whether petitioners realized income as a result of the transfer by Edward M. State to a corporation controlled by him of his interest in Farmington Funding Corporation in return for cancellation by the controlled corporation of State's indebtedness to it and the assumption of certain...
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