OPINION
FEATHERSTON, Judge:
Respondent determined deficiencies in the amounts of $58,276 and $43,300 in petitioner's Federal income tax for the fiscal years ended October 31, 1974, and October 31, 1976, respectively. Other issues having been settled by the parties, the only issue remaining for decision is whether liquidating distributions received by petitioner, the Estate of Henry C. Bickmeyer, deceased, from Hempstead Bus
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