Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent determined a deficiency in the Federal income tax of the petitioner for the taxable year 1966 in the amount of $107,115.93.
The petitioner has conceded the disallowance of entertainment expenses in the amount of $344.89. Consequently, the only issue presented for decision is whether the sale of the petitioner's interest in Flakice Corporation was a completed transaction in 1966...
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