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ROSEN v. COMMISSIONER

Docket No. 7179-71.

62 T.C. 11 (1974)

DAVID ROSEN AND VERA ROSEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 8, 1974.

Attorney(s) appearing for the Case

Jerome Kaplan, for the petitioners.

Alan E. Cobb, for the respondent.

QUEALY, Judge:

The respondent determined deficiencies in the Federal income tax of the petitioners for the taxable years 1965 and 1967 in the amounts of $3,481.33 and $87,010.81, respectively.

The principal issue for our determination is whether petitioner, David Rosen, realized gain under section 357(c)1 in the taxable year 1967, on the transfer of all the assets and liabilities of his sole proprietorship to a corporation...

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