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SIMPSON v. COMMISSIONER

Docket Nos. 1245-63, 2169-63.

43 T.C. 900 (1965)

W. H. B. SIMPSON AND KATHERINE M. SIMPSON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 30, 1965.

Attorney(s) appearing for the Case

Joseph E. McAndrews and Thomas A. Frazier, Jr., for the petitioners.

Winfield A. Gartner, for the respondent.

DRENNEN, Judge:

In these consolidated proceedings respondent determined deficiencies in petitioners' income tax for the taxable years 1958 and 1959 in the respective amounts of $233,532.55 and $231,899.97.

The only issue for decision is whether petitioners realized long-term capital gain in the amount of $908,697.951 upon the transfer of stocks, securities, and other property to Collins-Crain Co. (hereafter referred to as...

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