Memorandum Findings of Fact and Opinion
The respondent determined deficiencies in income, declared value excess profits and excess profits taxes against J. A. Folger and Company for the year 1940 in the respective amounts of $178,103.68, $109,000.39 and $207,539.07.
The issue in controversy is whether, as a result of a distribution in kind made by the petitioner in 1940, the petitioner realized taxable income to the extent of the difference between the fair...
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