JAMES M. CARTER, District Judge.
This appeal raises two major issues: (1) the application of section 482 of the Internal Revenue Code of 1954 [26 U.S. C.A. § 482], which allows the Commissioner to reallocate expenses of the taxpayer, to the fact situation in this case, and (2) an interpretation of section 351 of the Internal Revenue Code of 1954 [26 U.S.C.A. § 351], which allows the taxpayer to transfer property to a corporation in exchange for stock, without...
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