TANNENWALD, Chief Judge:
Respondent determined deficiencies in petitioner's Federal income tax in the amounts of $27,007, $24,480, and $23,945 for the taxable years 1974, 1975, and 1976, respectively. The sole issue for our determination is whether petitioner is entitled to a stepped-up basis in its assets, equal to the price paid for petitioner's stock by Cayuga Corp.
FINDINGS OF FACT
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