Memorandum Findings of Fact and Opinion
The respondent determined deficiencies of $166.50 and $451.72 in the petitioner's income taxes for the years 1939 and 1940, respectively.
The single issue is whether or not certain distributions received by the petitioner in the taxable years, in liquidation of Hazen, Trent & Harrell Company, were on complete liquidation of that corporation pursuant to a plan as provided in section 115 (c) of the Internal Revenue...
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