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CHODOS v. COMMISSIONER

Docket No. 784-76.

37 T.C.M. 1716 (1978)

T.C. Memo. 1978-413

Bernard Chodos and Gertrude Chodos v. Commissioner.

United States Tax Court.

Filed October 16, 1978.

Attorney(s) appearing for the Case

Stephen E. Lampf, David J. Pleva and John M. Clyne, Jr., 80 Main St., West Orange, N.J., for the petitioners. William M. Gross, for the respondent.

Memorandum Findings of Fact and Opinion

SCOTT, Judge:

Respondent determined deficiencies in petitioners' income tax for the calendar years 1971, 1972 and 1973 in the amounts of $16,696.18, $15,354.86 and $14,571, respectively.

Certain issues raised by the pleadings have been conceded by petitioners, leaving for our decision only whether stock of U.S. Home and Development Corporation received by Bernard Chodos was a gift or compensation.

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