HOWARD v. COMMISSIONER

Docket No. 62090.

32 T.C. 1284 (1959)

ROBERT S. HOWARD AND ANTOINETTE LEES HOWARD, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 28, 1959.


Attorney(s) appearing for the Case

Adam Y. Bennion, Esq., and Stafford R. Grady, Esq., for the petitioners.

Mark Townsend, Esq., and Thomas S. Greaves, Esq., for the respondent.


Respondent determined deficiencies in petitioners' income taxes for 1948, 1950, and 1951 in the respective amounts of $13,198.02, $36,413.85, and $109,033.16.

The three issues remaining for determination relate to the years 1948 and 1951:

1. What is petitioners' basis in 1,324 shares of stock for the purpose of computing gain upon a liquidating distribution received from a corporation in 1951?

2. Are petitioners entitled to deduct legal fees and other...

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