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WEIKEL v. COMMISSIONER

Docket No. 17990-81.

51 T.C.M. 432 (1986)

T.C. Memo. 1986-58

Maurice M. Weikel and Lorraine H. Weikel v. Commissioner.

United States Tax Court.

Filed February 10, 1986.

Attorney(s) appearing for the Case

Laurence L. Pillsbury, 225 Broadway, San Diego, Calif., for the petitioners. Karen Nicholson Sommers, for the respondent.

Memorandum Findings of Fact and Opinion

DRENNEN, Judge:

Respondent determined a deficiency in petitioners' Federal income tax in the amount of $1,750,273 for the taxable year 1974. The issue remaining for our decision1 is whether petitioners' transfer of stock from Dispersalloy, Inc. for stock in Johnson & Johnson qualifies as a tax-free reorganization under sections 354(a)(1)

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