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SHEREFF v. COMMISSIONER

Docket No. 19383-80.

77 T.C. 1140 (1981)

LOUIS H. SHEREFF AND ANNA L. SHEREFF, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 19, 1981.

Attorney(s) appearing for the Case

Louis H. Shereff, pro se.

Robert J. Alter, for the respondent.

OPINION

TIETJENS, Judge:

Respondent determined a deficiency of $16,743.62 in petitioners' 1977 Federal income tax. The sole issue for decision is whether, in determining the amount of realized gain or loss from the liquidation and distribution to them of Petro Realty Corp.'s assets under section 333,1 petitioners, who are qualified electing shareholders, must use the fair market value of appreciated real property owned...

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