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H & M AUTO ELECTRIC, INC. v. COMMISSIONER

Docket No. 20724-87.

92 T.C. 1269 (1989)

H & M AUTO ELECTRIC, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 15, 1989.

Attorney(s) appearing for the Case

Stephan A. Pezalla, for the petitioner.

Michael A. Urbanos, for the respondent.

OPINION

WILLIAMS, Judge:

The Commissioner determined a deficiency in petitioner's 1983 Federal income tax of $33,852. The issue we must decide is whether petitioner must recognize gain, pursuant to section 311(c),1 on the distribution of assets in complete redemption of a shareholder's interest.

The facts of this case have been fully stipulated pursuant to Rule 122, Tax Court Rules of Practice and Procedure, and...

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