ARUNDELL, Judge:
Respondent determined a deficiency in income tax for the calendar year 1961 in the amount of $128,057.39.
The issue is whether the cost to petitioner in 1961 of $260,257.96 for 5,000 shares of capital stock of Commercial Credit Co., which stock petitioner transferred in 1961 to Greyhound Rent-A-Car, Inc., pursuant to a second amendment to an agreement of sale entered into in 1959 between petitioner's assignor and Greyhound, represented...
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