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ESTATE OF APPLESTEIN v. COMMISSIONER

Docket No. 4788-79.

80 T.C. 331 (1983)

ESTATE OF MARGITA APPLESTEIN, DECEASED, LOUIS APPLESTEIN, ADMINISTRATOR, AND LOUIS APPLESTEIN, SURVIVING HUSBAND, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 2, 1983.

Attorney(s) appearing for the Case

Louis Applestein, pro se.

Richard J. Sapinski, for the respondent.

WILBUR, Judge:

Respondent determined a deficiency in petitioners' Federal income tax for 1973 in the amount of $19,531.48.1 The issues presented for our determination are (1) whether petitioners are taxable on the gain reported by their two children from the exchange of National Realty stock transferred to them by petitioner Louis Applestein after the approval of a merger of National Realty Corp. with United

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