Memorandum Findings of Fact and Opinion
HALL, Judge:
Respondent determined a $43,638.99 deficiency in petitioner's 1968 Federal income tax.
The issues to be decided are:
1. Whether petitioner-husband, a one-third shareholder in a corporation, received one-third of the assets of the corporation in exchange for his stock on liquidation of the corporation, or, as petitioners contend, a lesser amount.
2. The fair market value on the date...
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