COTTER v. COMMISSIONER

Docket No. 85621.

20 T.C.M. 1027 (1961)

T.C. Memo. 1961-202

Ralph E. Cotter, Jr., and Mabel O. Cotter v. Commissioner.

United States Tax Court.

Filed July 7, 1961.


Attorney(s) appearing for the Case

Frank T. Andrews, C. P. A., 593 Market St., San Francisco, Calif., for the petitioners. William T. Ivey, Esq., for the respondent.


Memorandum Opinion

RAUM, Judge:

Respondent determined a deficiency in petitioners' income tax for the taxable year 1955 in the amount of $13,541.73. The only matter presently in controversy involves the proper tax treatment under the 1954 Code of the transfer by petitioner Ralph E. Cotter, Jr. of his undivided one-half interest in 25 acres of undeveloped farm land to a corporation, Glenhaven, Inc., in exchange for shares of the corporation's stock. The facts...

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