Memorandum Findings of Fact and Opinion
TANNENWALD, Judge:
Respondent determined a deficiency of $459,542.01 in petitioners' 1955 income tax. The sole issue is whether the transfer of 27,000 shares of Bellanca Aircraft Corporation stock from L. Albert & Son to the Winfield Baird Foundation constituted income to petitioner David Baird or a gift to the Foundation.
Findings of Fact
Some of the facts have been stipulated and are found accordingly...
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