Memorandum Findings of Fact and Opinion
LEECH, Judge:
Respondent has determined a deficiency of $30,224 in petitioner's income tax for the calendar year 1941. An overpayment of $5,016.02 is claimed by petitioner. The issues submitted are: (a) whether petitioner realized a deductible loss upon the liquidation of a corporation wherein he surrendered his shares of its corporate stock and received stock of another corporation to which the liquidating corporation...
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