OPINION
FAY, Judge:
Respondent determined a deficiency of $3,211,019 in petitioner's 1978 Federal income tax. The only issue is whether petitioner properly computed the basis in its subsidiaries' stock in reporting gain from the sale of the stock.
The facts have been fully stipulated and are so found.
Petitioner Woods Investment Co., a Delaware corporation, had its principal office in Oklahoma City, Oklahoma, at the time it filed the...
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