Memorandum Findings of Fact and Opinion
LEECH, Judge:
Respondent has determined a deficiency of $223,498.95 in income tax of the petitioner for the calendar year 1938. The issues submitted are the amount of the tax liability resulting to petitioner (1) from the liquidation under section 112 (b) (7) of the Revenue Act of 1938, in December 1938 of Avalon Investment Corporation, a personal holding company, (hereinafter called "Avalon"), in which she was the...
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