IRWIN, Judge:
Respondent determined a deficiency of $5,844.01 in petitioners' income tax for calendar year 1963. Certain questions having been resolved by the parties, the sole issue presented is whether gain from the liquidation of a corporation, in which petitioner John E. Byrne was a shareholder, should have been recognized by petitioner in 1963—the year in which various securities (comprising in part the subject matter of the liquidation and held...
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