OPINION
SIMPSON, Judge:
The respondent determined a deficiency of $106,489.51 in the petitioner's 1965 Federal income tax. The issue to be decided is whether the petitioner acquired an item of "goodwill" when it purchased the stock of a corporation and paid an amount in excess of the fair market value of the underlying assests.
All of the facts were stipulated, and those facts are so found.
The petitioner, Peerless Investment Co.,...
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