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ALDERMAN v. COMMISSIONER

Docket No. 5935-68.

55 T.C. 662 (1971)

VELMA W. ALDERMAN, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 11, 1971.

Attorney(s) appearing for the Case

Bernard F. Bednarz, for the petitioner.

Vivian T. Martinez, Jr., for the respondent.

OPINION

DAWSON, Judge:

Respondent determined a deficiency of $4,568.42 in petitioner's Federal income tax for the year 1963. There are two issues for decision: (1) Whether section 357(c), I.R.C. 1954,1 applies when property is transferred pursuant to section 351(a) and the transferor issues a promissory note equal to the amount by which the liabilities assumed by the transferee exceed the adjusted basis of the assets transferred...

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