This is a proceeding for the redetermination of a deficiency of $118,226.69 in the petitioner's income tax for the year 1939. In 1939 the petitioner transferred to the Gremoco Corporation 3,256 shares of the preferred stock of that corporation for a cash consideration, and the principal question for decision is whether the petitioner received distributions in partial liquidation and is taxable on the entire amount of the gain realized, or whether he made a sale of capital...
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