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CLARK v. COMMISSIONER

Docket No. 9428-83.

86 T.C. 138 (1986)

DONALD E. CLARK AND PEGGY S. CLARK, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed February 6, 1986.

Attorney(s) appearing for the Case

Walter B. Slocombe, Daniel B. Rosenbaum, and Daniel M. Davidson, for the petitioners.

Kathleen E. Whatley, for the respondent.

TANNENWALD, Judge:

Respondent determined a deficiency in petitioners' Federal income taxes for the taxable year 1979 of $972,504.74. The sole issue for decision is whether the receipt by petitioners of cash (boot) as partial consideration under a plan of reorganization pursuant to sec. 368(a)(1)(A) and (a)(2)(D),1 should be treated as a dividend pursuant to sec. 356(a)(2), instead of long-term capital gain under sec. 356(a)(1)....

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