Memorandum Findings of Fact and Opinion
TRAIN, Judge:
Respondent determined a deficiency in petitioner's 1960 income tax of $85,900.11. The parties have settled several issues, and only two questions remain for decision: (a) the value of stock received by petitioner as consideration for the transfer of its business assets and (b) the allowance of a depreciation deduction for certain of those assets in the year of transfer.
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