Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency in petitioners' Federal income tax liability for the taxable year 1962 in the amount of $11,271.88.
Petitioners have conceded on brief that the October 20, 1961, offer and the November 3, 1961, acceptance constituted a valid contract to purchase 88.47 percent of the voting control of Lenk Manufacturing Company (Lenk). Therefore, the only issues remaining for our...
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