JOHNSTON v. COMMISSIONER

Docket No. 17069-79.

77 T.C. 679 (1981)

MARY ARNOLD SCHOELLKOPF JOHNSTON, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 24, 1981.


Attorney(s) appearing for the Case

William E. Collins and Thornton Hardie III, for the petitioner.

Linda L. Wong, for the respondent.


EKMAN, Judge:

Respondent determined a deficiency in petitioner's Federal income tax for the taxable year ending December 31, 1976, in the amount of $8,088.38. The issue for decision is whether $28,750 received by petitioner in redemption of a portion of her shares in a closely held corporation should be treated as a capital gain pursuant to sections 302(a) and 302(b)(1), I.R.C. 1954.1

FINDINGS OF FACT

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