Memorandum Findings of Fact and Opinion
TIETJENS, Judge:
The Commissioner determined a deficiency in income and excess profits tax of $45,802.27 for 1951. Petitioner claims an overpayment of $93,964.01 for the same year. The questions presented are: (1) Whether the basis of assets obtained by petitioner in the liquidation of certain corporations should be ascertained by allocating petitioner's cost of acquiring the stock of the liquidated corporations among...
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