STERRETT, Judge:
Respondent determined a deficiency in petitioner's Federal income tax for the calendar year 1970 in the amount of $22,699.
The issues presented for decision are: (1) Whether gain is recognized under section 357(c), I.R.C. 1954, upon the transfer by petitioner, in 1970, of the assets and liabilities of his sole proprietorship to his controlled corporation; (2) whether petitioner failed to include, for his 1970 taxable year, $2,094 of...
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