ATKINS, Judge:
The respondent determined a deficiency in income tax for the calendar year 1956 in the amount of $18,499.25.
The issue presented is whether taxable gain is to be recognized upon the exchange by the petitioners of their minority stock interest in one corporation for all of the stock of a second corporation which was, prior to the exchange, wholly owned by the first corporation.
FINDINGS OF FACT
Some of the facts have...
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