Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined deficiencies in the amounts of $78,294.41 and $81,359.41 in petitioner's Federal income taxes for 1964 and 1965, respectively. Other adjustments having been settled by the parties, the following issues remain for resolution:
1. The fair market value, if any, of a leasehold which petitioner acquired as part of the assets distributed in a liquidation pursuant to section...
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