OPINION
BRUCE, Judge:
Respondent determined a deficiency of $83,209.70 in petitioner's Federal income tax for its taxable year ended September 30, 1970. The issues presented for our decision are (1) whether petitioner, Virginia Materials Corp., constructively received a taxable distribution when its wholly owned subsidiary, Tidewater Industrial Development Corp., purchased shares of petitioner's stock, and if the first question is answered affirmatively...
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