OPINION
LARSEN, Justice.
Prior to October 3, 1960, Ray E. Lied and his son, Eugene R. Lied, conducted a partnership known as "Ray E. Lied & Son." On or about October 3, 1960, Ray and Eugene Lied organized a closely-held corporation, "Ray E. Lied & Son, Inc." to which was transferred most of the property, assets, business and good will of the partnership. The only stockholders were Ray and Eugene Lied, each holding 500 shares.
A stock purchase...
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