Memorandum Findings of Fact and Opinion
PIERCE, Judge:
The Commissioner determined deficiencies in the income taxes of the petitioners for the calendar years 1958 and 1960, in the amounts of $11,274.52 and $975.42, respectively.
The issues for decision are:
(1) Whether the "sale" in 1958 by petitioner Samuel Abrams of all his stock in a wholly-owned corporation for $100, was an arm's length bona fide transaction which entitles him to deduct...
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