Memorandum Findings of Fact and Opinion
SCOTT, Judge:
Respondent determined deficiencies of $81,847.32 and $12,646.18 in petitioner's Federal corporate income tax for the calendar years 1972 and 1973, respectively. Some of the issues raised by the pleadings have been disposed of by the parties, leaving for decision the following: Whether petitioner received the assets of Yellow Cab Company in a tax-free liquidation under section 332, I.R.C. 1954,
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