Memorandum Findings of Fact and Opinion
GOFFE, Judge:
Respondent determined a deficiency in the Federal income tax of T.J. Moss Tie Company (Delaware) for its taxable year ended June 30, 1964, in the amount of $1,663,429.25. Petitioner is the surviving corporation of a merger with the taxpayer and is liable for any Federal income tax which may be due from the taxpayer.
The issue arises from the purchase by the taxpayer of all the outstanding stock...
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