GOFFE, Judge:
The Commissioner determined a $143,064.22 deficiency in petitioner's Federal income tax for its taxable year ended March 31, 1969. The issues for decision are:
(1) The proper method of allocating the cost of constructing a road between three parcels of land adjacent to the road;
(2) Whether petitioner is a collapsible corporation as defined by section 341(b) of the Internal Revenue Code of 1954 and precluded thereby from the nonrecognition...
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