Respondent determined a deficiency in petitioner's income tax for the taxable year ended March 31, 1969, in the amount of $589,882.28.
The sole issue for determination is whether the plan of liquidation of Riggs-Young Corp., a subsidiary of the petitioner, was adopted subsequent to the time when petitioner owned at least 80 percent of the outstanding stock of Riggs-Young, thereby rendering section...
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