Memorandum Findings of Fact and Opinion
FEATHERSTON, Judge:
Respondent determined a deficiency in petitioners' joint Federal income tax for 1961 of $20,802.54. Some of the adjustments have been conceded by petitioners. The issues remaining for decision are: (1) Whether petitioners realized gain in 1961 from the exchange of machinery and equipment for stock of Pictorial Productions, Inc., and, if so, the amount of the gain; and, (2) whether 210 shares of...
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