The Commissioner determined deficiencies in income tax for the taxable years 1952 and 1953 in the amounts of $264,037.43 and $14,786.26, respectively. The question is whether or not section 112 (c) (1), 1939 Code, applies to a transaction in which petitioner received cash and stock in an acquiring corporation in exchange for all of the stock in another corporation, which became a subsidiary of the acquiring corporation, so that the taxable gain to be recognized is limited...
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