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KINGSLEY v. COMMISSIONER

Docket No. 9034-75.

72 T.C. 1095 (1979)

JERROLD L. KINGSLEY AND JUNE H. KINGSLEY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 17, 1979.

Attorney(s) appearing for the Case

Eugene J. Brenner and Michael L. Curtis, for the petitioners.

Peter D. Bakutes, for the respondent.

FAY, Judge:

Respondent determined a deficiency of $36,306 in petitioners' 1970 Federal income tax. The principal issue presented is whether certain shares of stock delivered to petitioner Jerrold L. Kingsley in connection with a tax-free reorganization are subject to the imputed interest rules of section 483.1 If section 483 is applicable, we must then decide how those shares are to be valued.

FINDINGS OF FACT

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