SIMPSON, Judge:
The respondent determined a deficiency of $213,909.24 in income taxes of the petitioners for the taxable year 1960. In this case, we have two issues — whether the corporation Mokan was in liquidation in 1960, and whether the respondent is collaterally estopped from raising that issue as a result of an earlier decision holding that Mokan was in liquidation in 1945.
FINDINGS OF FACT
Some of the facts were stipulated, and...
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