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WHITING v. COMMISSIONER

Docket Nos. 902-81, 904-81.

47 T.C.M. 1334 (1984)

T.C. Memo. 1984-142

Robert E. Whiting and Vernealle Whiting v. Commissioner. Richard L. Whiting and Mary Ann Whiting v. Commissioner.

United States Tax Court.

Filed March 22, 1984.

Attorney(s) appearing for the Case

Ernest Getz, 800 First National Bldg., Detroit, Mich., for the petitioners. Chauncey W. Tuttle, Jr., for the respondent.

Memorandum Opinion

CLAPP, Judge:

Respondent determined a deficiency in the 1976 income tax of Robert and Vernealle Whiting of $71,275.93 and a deficiency in the 1976 income tax of Richard and Mary Ann Whiting of $73,257.23. Because of concessions by petitioners, the only substantive issue in each case is whether Robert Whiting and Richard Whiting realized income when Fayette Tubular Products, Inc., discharged a portion of their debts on stock subscriptions...

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