McALLISTER, Chief Judge.
This is a petition for review of a decision of the Tax Court finding that the basis of petitioner's depreciable assets was $650,000.00, instead of $1,000,000.00, which petitioner contended it had paid for the tangible assets in question.
The government claimed, and the Tax Court found, that although, in the contract of purchase of the assets, the cost was set forth as $1,000,000.00, the actual value of the tangible assets was $650...
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