The respondent determined a deficiency of $153,121.86 in the income tax of the petitioners for 1949. The issues are the correctness of the respondent's action in determining that during 1949 a certain corporation distributed one-third of its net assets to petitioners in exchange for their one-third stock in it and that as the result of the distribution the petitioners during 1949 (1) realized capital gain of $469,333.34 on stock of the corporation, (2) realized capital gain...
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