Memorandum Findings of Fact and Opinion
PIERCE, Judge:
This proceeding involves a deficiency in petitioner's income tax for 1958 in the amount of $177,185.22. Some of the issues raised in the pleadings have been settled by agreement of the parties and some of the facts have been stipulated. The sole remaining question in issue is whether petitioner or Indianapolis Forwarding Co., (IFC) whose stock petitioner acquired in 1958, is entitled to a net operating...
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