Memorandum Opinion
TANNENWALD, Judge:
Respondent determined deficiencies in the Federal income taxes of petitioners Simonson and petitioners Woodward for 1970 of $19,160.28 and $6,647.00, respectively. The issue for decision is whether petitioners must recognize gain on their transfer of stock to Mergers and Acquisitions, Inc.
All of the facts and exhibits in this case were fully stipulated and are incorporated herein by this reference.
Petitioners...
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