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SIMON v. COMMISSIONER

Docket No. 73722.

20 T.C.M. 1309 (1961)

T.C. Memo. 1961-251

David and Renee Simon v. Commissioner.

United States Tax Court.

Filed August 31, 1961.

Attorney(s) appearing for the Case

Richard Z. Steinhaus, Esq., for the petitioners. Colin C. MacDonald, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

Respondent determined a deficiency in petitioners' income tax for the taxable year 1950 in the amount of $18,692.86.

The only issue for decision is whether petitioners may treat the amount of $55,000 received by David Simon (hereinafter referred to as David) in 1950 from Universal Industries, Inc. (hereinafter referred to as Universal), as gain from the sale of a capital asset held for more...

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