Memorandum Opinion
FAY, Judge:
Although other issues are involved, the tax deficiencies determined in these cases arise primarily from a transaction between petitioners, Karel and Clara Waterman (Mr. Waterman and Mrs. Waterman, respectively), and the Trans-Pacific Capital Corporation (Trans-Pac). Initially, respondent determined the tax consequences arising from that transaction should be accounted for in petitioners' 1968 taxable year. Thus, in separate...
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