SCOTT, Judge:
Respondent determined a deficiency in petitioner's income tax for the calendar year 1959 in the amount of $220,046.20. The issues for decision are whether a transfer of appreciated stock in a family-held corporation by petitioner to his wife pursuant to an agreement incident to a divorce granted in Oklahoma was a nontaxable division of property or a taxable transfer and, if the latter, the fair market value of the stock on the date of transfer...
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