Memorandum Opinion
SCOTT, Judge:
Respondent determined a deficiency in petitioners' Federal income tax for the taxable year ended December 31, 1970, in the amount of $9,713.20. The only issue for decision is whether the transfer of 16 shares of nonvoting common stock of Furr Realty Company by petitioner Don Furr to a related corporation, within the meaning of section 304, I.R.C. 1954,
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