COUPE v. COMMISSIONER

Docket No. 861-65.

52 T.C. 394 (1969)

LESLIE Q. COUPE AND MAYBELLE COUPE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 11, 1969.


Attorney(s) appearing for the Case

Lee M. Galloway, for the petitioners.

Gordon B. Cutler, for the respondent.


FORRESTER, Judge:

Respondent has determined deficiencies in petitioners' Federal income taxes for the calendar years 1960 and 1961 in the amounts of $16,807.34 and $47,453.81, respectively.

The issues for decision are:

Whether the taxpayers sold their entire farm for cash, or whether they exchanged part of it for property of like kind. If there was an exchange, the amount of the unrecognized gross sales price attributable to petitioners' exchange...

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