Memorandum Findings of Fact and Opinion
TRAIN, Judge:
A deficiency in 1956 income tax of $14,649.84 and an overassessment in 1957 income tax of $609.56 have been determined. Respondent having conceded a depreciation adjustment, the sole issue for decision is whether a distribution of the stock of a newly-organized subsidiary corporation to the stockholders of the parent corporation qualifies as a nontaxable transaction within the provisions of section 355...
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