Memorandum Findings of Fact and Opinion
HARLAN, Judge:
The respondent determined deficiencies in income tax for the calendar year 1939 in the amount of $3,698.09 against each of the petitioners. The sole questions presented are whether the respondent correctly determined the amount of income realized by petitioners as a result of the transfer in 1939 of a part of the assets of a partnership to a newly organized corporation, and whether any gain realized...
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