NOLAND v. COMMISSIONER

Docket No. 40531.

12 T.C.M. 1003 (1953)

Ray A. and Dessie T. Noland v. Commissioner.

United States Tax Court.

Entered August 31, 1953.


Attorney(s) appearing for the Case

Karl M. Ruppenthal, Esq., 1711 Guinda Street, Palo Alto, Calif., for the petitioners. R. G. Harless, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

The respondent determined a deficiency in income tax against the petitioners for the year 1945 in the amount of $888.34. The questions presented in this proceeding are whether the petitioners are to be taxed upon the receipt of shares of stock of TransWorld Airlines, Inc. and whether the statute of limitations barred the deficiency determined.

Findings of Fact

The facts are found as stipulated. The following...

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