Memorandum Findings of Fact and Opinion
The Commissioner determined a deficiency of $9,205.37 in petitioners' income tax for the year 1962. The principal question is what part if any of the taxpayer's one-third share of gain on sale of certain property to a corporation is entitled to nonrecognition under sections 351 and 357, I. R. C. 1954.
Findings of Fact
The two stipulations of facts and the exhibits attached thereto are incorporated herein...
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