The Commissioner determined deficiencies in income tax against the Luff Co. and against the remaining petitioners as transferees of the assets of the Luff Co. for the years 1957 and 1958 in the amounts of $2,277.04 and $8,960.98, respectively. A portion of the deficiency asserted for 1957 was due to the recomputation by the Commissioner of the net operating loss to be carried back from the year 1960. The only issue remaining for decision is whether there was a sale by the...
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