Memorandum Findings of Fact and Opinion
QUEALY, Judge:
The respondent has determined a deficiency of $5,778.49 in Federal income taxes filed by petitioners for the year 1965. The only question involved relates to the gain or income realized by petitioners on account of the transfer of assets and liabilities of Keystone Masonry Company, a sole proprietorship, to Keystone Masonry, Inc., a corporation, under
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