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FEHRS FINANCE COMPANY v. COMMISSIONER

Docket No. 2136-69.

58 T.C. 174 (1972)

FEHRS FINANCE COMPANY, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed May 1, 1972.

Attorney(s) appearing for the Case

William A. Cromartie and William E. Barrows, for the petitioner.

James T. Finlen, Jr., for the respondent.

SIMPSON, Judge:

The respondent has determined a deficiency of $32,459.07 in the petitioner's Federal income tax for the year ended November 30, 1965. In a transaction which we conclude was a redemption under section 304(a)(1) of the Internal Revenue Code of 1954,1 the petitioner acquired stock in exchange for a promise to pay two annuities, and immediately thereafter it sold such stock prior to making any annuity payments. To determine...

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