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PALMER v. COMMISSIONER

Docket No. 2557-71.

62 T.C. 684 (1974)

DANIEL D. PALMER AND AGNES H. PALMER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 27, 1974.

Attorney(s) appearing for the Case

Bernard J. Long, Jr., and James A. Treanor III, for the petitioners.

Robert D. Grossman, Jr., and Ava D. Poe, for the respondent.

SIMPSON, Judge:

The respondent determined a deficiency of $178,309.72 in the Federal income tax of the petitioners for the year 1966. Two issues are presented for decision. The first is whether in substance, as well as in form, a contribution of stock by the petitioners preceded the redemption of such stock, when the redemption took place the very next day. In the event we find that the contribution, in substance, preceded the redemption, we must determine...

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