Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1954 in the amount of $1,335,740.06.
The issues for decision are as follows:
(1) Whether 279,000 shares of Reynolds Spring Company stock issued to petitioner in a taxable exchange had an ascertainable fair market value on December 29, 1954; and
(2) If the stock had an ascertainable fair market value...
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