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ESTATE OF SCHNEIDER v. COMMISSIONER

Docket No. 6234-79.

88 T.C. 906 (1987)

ESTATE OF AL J. SCHNEIDER, DONALD J. SCHNEIDER, ET AL., PERSONAL REPRESENTATIVES, AND AGNES SCHNEIDER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 15, 1987.

Attorney(s) appearing for the Case

Robert E. Nelson and Arthur Kaftan, for the petitioners.

Edward J. Roepsch, for the respondent.

CHABOT, Judge:

Respondent determined deficiencies in Federal individual income tax against Al J. Schneider and Agnes Schneider for 1975 and 1976 in the amounts of $17,745.84 and $21,415, respectively. After concessions by both sides, the issues for decision are as follows:

(1) Whether certain dispositions of stock by Al J. Schneider constitute (a) sales of stock by him to employees or (b) redemptions of the stock from him.

(2) If the dispositions...

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