MADDEN, Judge.
The taxpayer, The Ainsley Corporation, has filed this petition for review of a decision of the Tax Court of the United States. This court has jurisdiction under Section 7482 of the Revenue Code of 1954.
The taxpayer in its federal income tax return for 1958 took a deduction from income of $102,770, because, it said, the shares of stock of Santa Clara Frosted Foods Company, hereinafter called Santa Clara, owned by the taxpayer, and having a basis...
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