Memorandum Findings of Fact and Opinion
HARRON, Judge:
The respondent determined a deficiency of $108,885.37 in the income tax liability of Stephens Brothers, Incorporated, for its final fiscal year, November 1, 1959, to October 4, 1960. Stephens Brothers, Incorporated, is the predecessor of Stephens Marine, Inc., the petitioner. The issues for decision are:
(1) Whether there is includable in the...
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