The Commissioner determined deficiencies in the income tax of petitioner for the taxable year ended March 31, 1963, and the taxable period beginning March 29, 1965, and ending August 31, 1965, in the respective amounts of $25,973.15 and $79,311.41.
After concessions by both parties, the issue presented is whether the Commissioner properly "allocated" income to the petitioner, under the terms of section 482, I.R.C. 1954, in respect of its transfer of 52 houses to its...
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