Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The respondent determined deficiencies in income tax for the years 1950, 1951, 1952 and 1953, in the respective amounts of $33,949.60, $234.07, $1,225.71 and $946.45. The issues concern the valuation of a contract distributed to Frank H. Hoy on liquidation of a corporation in 1950 and the tax treatment of amounts received in the taxable years pursuant to that contract. The petitioners filed joint returns...
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