BROWN v. COMMISSIONER

Docket No. 2841-68.

54 T.C. 1475 (1970)

ROYCE W. BROWN AND PATTY L. BROWN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed July 14, 1970.


Attorney(s) appearing for the Case

Charles B. Lutz, Jr., and John K. Speck, for the petitioners.

J. C. Linge, for the respondent.


The Commissioner determined a deficiency in the income tax of petitioners for the year 1963 in the amount of $19,405.46. Petitioners claim an overpayment for that year in the amount of $3,663.65. At issue is whether amounts received in respect of petitioner Royce W. Brown's assignment of interests in certain real properties to a controlled corporation are capital gains or ordinary income.

FINDINGS OF FACT

Some of the facts have been stipulated and are incorporated...

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