Memorandum Findings of Fact and Opinion
FAY, Judge:
The Commissioner determined a deficiency in petitioners' income tax for the year 1960 in the amount of $61,135.93. Petitioners, through an amended return and in their petition for the year 1960, claim an overpayment in the amount of $21,942.71. The principal issue for decision is whether the Tabery Corporation, a corporation whose stock in owned 100 percent by petitioner Fred J. Tabery, redeemed, as that...
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