CARRINGTON v. COMMISSIONER

Docket No. 6390-69.

30 T.C.M. 950 (1971)

T.C. Memo. 1971-222

Walter R. Carrington and Ada Raye Carrington v. Commissioner.

United States Tax Court.

Filed August 31, 1971.


Attorney(s) appearing for the Case

E. Richard Criss, Jr., 900 Brown Bldg, Austin, Tex., for the petitioners. W. Read Smith, for the respondent.


Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1966 in the amount of $5,573.71. The sole issue to be decided is whether petitioners realized dividend income as the result of a series of transactions whereby they contributed 51 percent of the stock of a corporation to a church and the corporation thereafter distributed a residence to the church in redemption of such stock.

Walter R. Carrington...

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