McLAUGHLIN, Circuit Judge.
The dispute here centers around the disposal of the taxpayer's business. The Tax Court found that the petitioner sold its assets and realized a profit. Petitioner contends that it distributed its assets in liquidation to its stockholders with consequently no profit involved and, therefore, no tax. The pertinent parts of the Revenue Act of 1936 are set out in the footnote.
The Tax Court found the following...
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