CLARK, Circuit Judge.
The sole issue presented to us on this petition contesting a deficiency assessment of excess profits taxes arises by reason of a difference in valuation of property received by taxpayer in payment for 200 shares of its non-par value stock and constituting "equity invested capital" for tax assessment purposes. I.R.C. § 718, 26 U.S. C. The value set by the taxpayer and supported throughout by it was $100,000; this figure was reduced by respondent...
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