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PARSONS v. COMMISSIONER

Docket No. 4816-68.

54 T.C. 54 (1970)

GEORGE W. PARSONS AND EMMA J. PARSONS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 21, 1970.

Attorney(s) appearing for the Case

Arthur A. Atha, for the petitioners.

Barry N. Mosebach, for the respondent.

SCOTT, Judge:

Respondent determined a deficiency in petitioners' income tax for the calendar year 1963 in the amount of $1,081,68.

The only issue for decision is whether petitioners realized a long-term capital gain in February 1963 when George W. Parsons transferred ownership of 50 shares of stock of Lucey Export Corp. to that corporation and the Lucey Export Corp. transferred to him a life insurance policy on his life.

FINDINGS OF FACT

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