OPINION
FAY, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for the taxable years 1964 and 1967 in the amounts of $2,483.43 and $3,387.65, respectively.
The issues presented for our consideration are: (1) Whether the 50 shares of no-par-value common stock of Aintree Stables, Inc. (hereinafter referred to as Aintree or the corporation), that petitioner acquired on May 20, 1964, were issued pursuant to a written...
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