The Commissioner determined a deficiency of $48,372.16 in petitioners' income tax for 1964. The only issue is whether distributions by Medco Electronics Co., Inc., to its shareholders were liquidating distributions under sections 331 and 346, I.R.C. 1954, or whether such distributions were incident to a corporate reorganization and were taxable as dividends under section 356 (a) (2).
FINDINGS OF FACT
The parties have stipulated certain facts, which, together...
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