Memorandum Findings of Fact and Opinion
SWIFT, Judge:
Respondent determined deficiencies in petitioner's Federal income tax for 1975 and 1976 in the amounts of $7,367 and $32,005, respectively. After concessions by petitioner, the issues for decision concern (1) the allocation of petitioner's cost basis in stock it owned in a subsidiary corporation to the various assets of that subsidiary corporation upon liquidation of the subsidiary into petitioner and...
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