The respondent determined a deficiency in personal holding company surtax for 1947 in the amount of $232.49 against the 1356 Fifth Avenue Corporation and the liability of petitioner therefor as transferee. The sole issue is whether certain interest received by the transferor in the taxable year constituted "rent" under section 502 (g) of the Internal Revenue Code of 1939.
FINDINGS OF FACT.
A stipulation of facts was filed by the parties and we find the facts...
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