ESTATE OF BYRD v. COMMISSIONER

Docket No. 3848-64.

46 T.C. 25 (1966)

ESTATE OF OTIS E. BYRD, DECEASED, JIMMIE LOU BYRD, ADMINISTRATRIX, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 6, 1966.


Attorney(s) appearing for the Case

W. G. Hardwick, for the petitioner.

Robert W. Goodman, for the respondent.


OPINION

ATKINS, Judge:

The respondent determined a deficiency in income tax of $64,856.64 against the petitioner-estate for its taxable year 1959. The only issue presented is whether distributions received by the estate upon the redemption of stock of three corporations should be treated, under section 303 of the Internal Revenue Code of 1954, as distributions in exchange for the stock so redeemed, as contended by the petitioner, or whether the amounts...

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