OPINION
RAUM, Judge:
The Commissioner determined a deficiency of $18,066.81 in petitioner's income tax for the taxable year ended April 30, 1966. The only issue presented for decision is whether gain realized by petitioner on the sale of its property pursuant to a plan of complete liquidation qualifies for nonrecognition under the provisions of section 337, I.R.C. 1954. The resolution of that question depends upon the applicability of section 337...
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