MEMORANDUM OPINION
RUWE, Judge:
Respondent determined a deficiency of $93,767 in petitioner's 1979 Federal income tax. The sole issue for decision is whether petitioner overstated the basis of assets acquired from Chemetron Corp. in 1979 by $3,081,584.
Some of the facts have been stipulated and are so found. The stipulation of facts and attached exhibits are incorporated herein by this reference. At the time the petition was filed in this case, petitioner...
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