Memorandum Findings of Fact and Opinion
DRENNEN, Judge:
Respondent determined a deficiency in petitioners' income tax for the calendar year 1970 in the amount of $376,940. The issues presented for our decision are:
(1) Whether a transfer of a corporation's own stock to it by Omar L. Ash gave rise to a long-term capital gain and a section 162,
(2) Whether petitioners are entitled to...
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