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DRUMMOND v. COMMISSIONER

Docket No. 87296.

22 T.C.M. 485 (1963)

T.C. Memo. 1963-105

William M. Drummond and Ruby B. Drummond v. Commissioner.

United States Tax Court.

Filed April 11, 1963.

Attorney(s) appearing for the Case

Richard F. Stone, Esq., Allied Arts Bldg., Lynchberg, Va., for the petitioners. Douglas O. Tice, Jr., Esq., for the respondent.

Memorandum Findings of Fact and Opinion

FISHER, Judge:

Respondent determined deficiencies in petitioners' income taxes for the years and in the amounts as follows:

  Year             Deficiency

  1957..........    $704.53
  1958..........     508.81

The only significant issue is whether the fair market value of Quality Foods Co-Operative, Incorporated, notes received by petitioners in 1957 and 1958 in exchange for revolving fund...

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