KUNSMAN v. COMMISSIONER

Docket No. 5399-65.

49 T.C. 62 (1967)

DONALD H. KUNSMAN AND LEE N. KUNSMAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 2, 1967.


Attorney(s) appearing for the Case

David E. Crabtree, for the petitioners.

B. David Freundlich, for the respondent.


MULRONEY, Judge:

Respondent has determined a deficiency in petitioners' 1962 income tax in the amount of $19,167.57.

The issues in the case are (1) whether a certain amount received by petitioner from his corporate employer in 1962 with respect to his surrendering his options to purchase employer's stock is taxable as ordinary income, and (2) whether petitioner suffered a deductible casualty loss in 1962 with respect to his swimming pool at his home...

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