The Commissioner determined deficiencies in income tax against petitioners for their taxable years 1958, 1959, and 1960 in the amounts of $1,653.71, $79,730.97, and $ 2,176.41, respectively, and an addition to tax under section 6653(a) of $3,986.55 for 1959. All issues have been settled except the question whether the distribution of $168,922.55 from the Madison Trust to petitioner Harold D. Greenwald in 1959 should be taxable as ordinary income or as long-term capital gain...
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