EDWARDS v. COMMISSIONER

Docket No. 33702.

19 T.C. 275 (1952)

EDWARD W. EDWARDS AND ELEANORE Z. EDWARDS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 21, 1952.


Attorney(s) appearing for the Case

Orie S. Ware, Esq., James C. Ware, Esq., and Frank Gofton Ware, Esq., for the petitioners.

Wm. R. Bagby, Esq., for the respondent.


OPINION.

JOHNSON, Judge:

Respondent has determined a deficiency of $353,663.46 in petitioners' income tax for the calendar year 1944.

The sole issue before us is whether the compromise of an indebtedness, evidenced by two notes, resulted in a reduction of basis of common stock; the stock was originally deposited as collateral security, later withdrawn, and after the compromise sold. Respondent made certain other adjustments to the petitioners...

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