Memorandum Opinion
DRENNEN, Judge:
Respondent determined a deficiency of $105,348.91 in petitioner's Federal income tax for its taxable year ended May 31, 1964.
Petitioner is a corporation organized under the laws of the State of Mississippi, its principal office being located in Flowood, Miss., at the time it filed its petition herein. On January 24, 1964, petitioner purchased 96.60 percent of the capital stock of the Flowood Corporation, a Mississippi...
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