Memorandum Findings of Fact and Opinion
GERBER, Judge:
Respondent, by means of a statutory notice of deficiency, determined deficiencies in petitioners' Federal income tax for taxable years 1980, 1981, and 1983 in the amounts of $7,320.96, $157,601.08, and $6,535.80, respectively.
After concessions, the issues for our consideration are: (1) Petitioner husband's adjusted basis in the stock and notes of his solely owned S corporation for purposes of...
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