SIMPSON, Judge:
The respondent determined deficiencies of $70,896 in the Federal income tax of the petitioner for each of the years 1966 and 1967. The parties are now in agreement that if we find a deficiency, such deficiency is in the tax for the year 1967. The sole issue for decision is whether the petitioner received 170,414 shares of stock as part of a transaction which qualified as a reorganization under section 368(a)(1)(B) of the Internal Revenue Code...
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