ATKINS, Judge:
The respondent determined deficiencies in income tax for the taxable years 1961, 1962, 1963, 1964, and 1965 of $19,053.29, $24,889.78, $17,224.10, $16,664.45, and $24,083.80, respectively. The parties having reached agreement as to certain issues, the issues remaining for determination are (1) whether a purported assignment by petitioner of all his interest in a partnership to a corporation of which he was the sole stockholder was effective to...
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