Memorandum Opinion
ARUNDELL, Judge:
Respondent determined a deficiency in income tax for the calendar year 1959 in the amount of $61,260.89.
The only issue is whether petitioner is entitled, in computing its taxable income for the calendar year 1959, to deduct, under section 164, income taxes paid to the Commonwealth of Virginia with respect to income from a liquidating dividend received by petitioner...
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