Memorandum Findings of Fact and Opinion
BRUCE, Judge:
Respondent determined a deficiency in the income tax of petitioners for the year 1959 in the amount of $35,570.49. The sole issue is whether long-term capital gain realized upon the sale of stock is taxable to petitioners or is taxable to a controlled corporation to which the stock was transferred pursuant to a contract whereby the corporation agreed to sell the stock upon receipt.
Findings of...
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