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ORR v. COMMISSIONER

Docket No. 6807-78.

78 T.C. 1059 (1982)

WILLIAM P. ORR AND SARA J. ORR, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 17, 1982.

Attorney(s) appearing for the Case

Meyer Weiner, for the petitioners.

Kenneth J. Rubin, for the respondent.

WILES, Judge:

Respondent determined deficiencies in petitioners' 1973 and 1974 Federal income taxes of $65,230 and $1,303, respectively. After concessions,1 the issues for decision are: (1) Whether petitioners transferred all the assets of their sole proprietorship, Schoolroom Tours, to their controlled corporation in exchange for stock and the corporation's assumption of Schoolroom Tours's liabilities; (2) whether petitioners recognized...

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