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accounting additional agent agreement allowed amount appears application assessment assets basis bond Burch Bureau capital gain charge claim collection Commissioner common Company computed consideration considered contract corporation cost course death decision deduction deficiency depreciation determined distribution dividend earnings effect estate tax excess exchange expenses fact fair Federal filed gain gift Government held holding included income tax interest Internal Revenue Code inventory involved issue liability limited liquidation loss marital deduction means ment method Office operating ordinary paid partnership patent payment period possible preferred present prior problem proceeds profits provisions purchase question reason received represent respect result rule securities sell settlement shares situation spouse Staff stockholders supra Tax Court taxable Taxation taxpayer term tion transaction transfer Treasury trust United York