Memorandum Findings of Fact and Opinion
JOHNSON, Judge:
Respondent determined a deficiency in income tax for the year 1944 in the amount of $183,397.06. The issues before us are as follows:
(1) In a corporate reorganization, was the receipt of stock by petitioner a taxable dividend?
(2) In the alternative, if the transaction was not tax free, is the gain taxable as a long-term capital gain?
(3) Again, in the alternative, if the transaction...
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