MEMORANDUM OPINION
FOLEY, Judge:
By notice dated June 29, 1998, respondent determined deficiencies in, and penalties relating to, petitioner's 1993, 1994, and 1995 Federal income taxes. After concessions, the sole issue for decision is whether discharge of indebtedness income that is excluded, pursuant to section 108, from the gross income of an S corporation increases the basis of petitioner's S corporation stock. The parties submitted this case fully stipulated...
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