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SEDA v. COMMISSIONER

Docket No. 21201-82.

82 T.C. 484 (1984)

LAVERNE V. SEDA AND LAVERNE E. SEDA, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 19, 1984.

Attorney(s) appearing for the Case

Frank M. Cavanaugh, for the petitioners.

Mark H. Howard, for the respondent.

OPINION

FAY, Judge:

Respondent determined deficiencies in petitioners' Federal income tax as follows:

Year                    Deficiency

1979 .................   $22,015
1980 .................    17,801

The issues before us are (1) whether the redemption of all petitioners' stock in a certain corporation was taxable as a dividend distribution under section 3011 or as a long-term...

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