OPINION.
TIETJENS, Judge:
This proceeding involves a deficiency in income tax for the taxable year 1954 in the amount of $16,875, and an addition thereto under section 294(d)(2) of the 1939 Code in the amount of $1,012.50.
The issue for decision is whether the transfer by the Christopher Construction Company of a portion of its assets to E. P. Coady and Co. in exchange for all of the Coady Company's stock, and the subsequent distribution by...
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