HORWITH v. COMMISSIONER

Docket No. 1528-76.

71 T.C. 932 (1979)

THEODORE M. HORWITH AND HAZEL M. HORWITH, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 28, 1979.


Attorney(s) appearing for the Case

William R. Nicholas and Robert E. Bennett, Jr., for the petitioners.

James D. Vandever, for the respondent.


GOFFE, Judge:

The Commissioner determined deficiencies in petitioners' Federal income tax for the taxable years 1971 and 1972 in the respective amounts of $1,371 and $12,400. Concessions having been made, the only issue remaining for our decision is whether petitioners properly valued certain stock received by them in 1972 for purposes of computing income under section 83(a)(1), I.R.C. 1954.1

FINDINGS OF FACT

Some...

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