HOYT, Judge:
Respondent determined deficiencies in petitioners' Federal income taxes in the amounts of $1,083.98, $1,354.87, and $1,161.14 for the taxable years 1962, 1963, and 1964, respectively.
The issues presented for decision are:
(1) Whether the forgiveness by a subchapter S corporation of indebtedness owed by a shareholder should be treated as a distribution of property resulting in a corresponding reduction of the basis of the shareholder...
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