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FLAMM v. COMMISSIONER

Docket No. 6215-66.

28 T.C.M. 1487 (1969)

T.C. Memo. 1969-287

Donald J. Flamm and Etelle Flamm v. Commissioner.

United States Tax Court.

Filed December 24, 1969.

Attorney(s) appearing for the Case

Arthur H. Goodman, for the petitioners. John B. Murray, Jr., for the respondent.

Memorandum Opinion

TANNENWALD, Judge:

Respondent determined a deficiency of $54,241.74 in petitioners' income tax for the taxable year ended December 31, 1962. The sole issue for decision is whether the petitioners realized $75,000 of dividend income by reason of a bargain purchase of unimproved land from Flamm Realty Corporation. The parties are in agreement that if the Court finds that the fair market value...

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