PIERCE, Judge:
The respondent determined a deficiency in the income tax of petitioners for the calendar year 1957, in the amount of $75,518.29.
The issues for decision are:
Where a corporation which had only two stockholders, and in which the petitioner held the minority stock interest, purchased or redeemed all the shares of its majority stockholder for a price of $113,000, and then canceled such shares, did this transaction —
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