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MALKAN v. COMMISSIONER

Docket No. 4788-66.

54 T.C. 1305 (1970)

ARNOLD MALKAN AND AUDREY MALKAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 17, 1970.

Attorney(s) appearing for the Case

Whitfield J. Collins and Allan Howeth, for the petitioners.

Harry H. Ellis, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1958 in the amount of $51,469.07. Certain issues have been settled by the parties. The issues remaining for decision are as follows:

(1) Whether the sale of 10,500 shares of stock was made by petitioner Arnold Malkan or by four trusts of which he was the settlor-trustee.

(2) What was the proper basis of the shares which were sold.

FINDINGS...

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