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PRESCOTT v. COMMISSIONER

Docket No. 3141-73.

66 T.C. 128 (1976)

EDWARD J. PRESCOTT AND WANDA D. PRESCOTT, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 21, 1976.

Attorney(s) appearing for the Case

A. H. Michals, for the petitioners.

David J. Duez and Jay B. Kelly, for the respondent.

IRWIN, Judge:

Respondent has determined a deficiency in petitioners' Federal income tax for the calendar year 1969 in the amount of $108,051.78, plus an addition to tax under section 6653(a)1 of $5,402.59. Various concessions having been made, the issues remaining for our decision are whether the termination of section 1361 status pursuant to section 1361(n)(2) should be treated as a corporate liquidation under section 331, whether...

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