Memorandum Findings of Fact and Opinion
WILES, Judge:
Respondent determined the following deficiencies in petitioners' Federal income taxes:
Year Deficiency 1970 ................ $ 2,166.34 1971 ................ 15,668.88 1972 ................ 741.48
The issues for decision are:
1. Whether petitioner Frank P. Battaglia received "other property" within the meaning of section 351(b)
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