JONES v. COMMISSIONER

Docket No. 3026-72.

61 T.C. 78 (1973)

LAURENCE D. JONES AND OLGA JONES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 23, 1973.


Attorney(s) appearing for the Case

Thomas D. Roberts, for the petitioners.

Joyce Elaine Britt and Peter D. Bakutes, for the respondent.


OPINION

RAUM, Judge:

The Commissioner determined a $40,435 deficiency in petitioners' 1969 income tax. The sole remaining issue involves ascertainment of the basis of certain shares of stock received by petitioner Olga Jones in 1953 out of the remainder of a trust that had been created in 1915. The outcome depends upon whether the "time of * * * acquisition" of the shares, under section 1015(c), I.R.C. 1954 (relating to transfers in trust before January...

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