Memorandum Findings of Fact and Opinion
IRWIN, Judge:
Respondent determined deficiencies in petitioners' income tax for the calendar years 1969, 1970 and 1971 as follows:
Year Deficiency 1969 ....... $1,804.96 1970 ....... 9,656.08 1971 ....... 3,063.00
Several concessions have been made, leaving for our resolution: the fair market value of stock in American Truck Lines, Inc., at the time of its contribution...
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