Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The respondent determined a deficiency in petitioner's income tax for the calendar year 1954 in the amount of $630,033.33.
The basic question for decision is whether the petitioner, which had experienced substantial changes in the character of its business, its name, its place of operation, its management, and its capital structure — as the result of the discontinuance of its former business...
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