Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency in income tax and victory tax of $6,455.83 for the year 1943. The primary question to be determined is whether the Grew Real Estate Trust is an association taxable as a corporation under section 3797 (a) (3), I. R. C. If held not to be such an association, a further question to be determined is petitioner's basis of 71 shares of stock of Hazelwood Corporation.
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