Memorandum Findings of Fact and Opinion
SIMPSON, Judge:
Respondent determined deficiencies in income tax of petitioner, The Piedmont Corporation, for its taxable years ending April 30, 1960, April 30, 1961, and April 30, 1962, in the respective amounts of $22,993.73, $1,257.91, and $7,031.29. The primary issue in this case is whether the assignment to petitioner of certain option rights held by its sole stockholders in return for $10,000 cash and $160,000...
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