The Commissioner determined a deficiency in petitioners' income tax for the taxable year ended December 31, 1955, in the amount of $24,437.40; of this amount, $1,163.69 constituted an addition for negligence under section 6653(a) of the Internal Revenue Code of 1954.
At issue is whether $39,800 received by petitioners in 1955 from a corporation, substantially all of the stock of which was owned by them, in redemption of stock of another corporation was taxable as...
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