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LYNCH v. COMMISSIONER

Docket No. 9509-79.

83 T.C. 597 (1984)

WILLIAM M. LYNCH AND MIMA W. LYNCH, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 22, 1984.

Attorney(s) appearing for the Case

Donald R. Share and Richard L. Greene, for the petitioners.

Charlotte Mitchell, for the respondent.

SIMPSON, Judge:

The Commissioner determined deficiencies in the petitioners' Federal income tax of $15,465.80 for 1974 and $389,852.27 for 1975. After concessions, the sole issue for decision is whether the redemption of all of the petitioner's stock in W.M. Lynch Co. is taxable as dividend distributions under section 301 of the Internal Revenue Code of 19541 or as long-term capital gains under section 302(a). The answer turns on...

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