CARTER v. COMMISSIONER

Docket No. 82438.

36 T.C. 128 (1961)

GEO. S. CARTER AND JAYE CARTER, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 21, 1961.


Attorney(s) appearing for the Case

Lawrence R. Bloomenthal, Esq., for the petitioners.

Buckley D. Sowards, Esq., for the respondent.


MULRONEY, Judge:

The respondent determined a deficiency in petitioners' income tax for the year 1953 in the amount of $641.63.

The only question in the case is whether George S. Carter realized additional compensation when he purchased from his employer corporation 300 shares of its treasury stock for $8,400 when the fair market value of the stock at that time was $9,487.50.

FINDINGS OF FACT.

...

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