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HUTCHESON v. COMMISSIONER

Docket No. 8886-94.

71 T.C.M. 2425 (1996)

T.C. Memo. 1996-127

Richard L. Hutcheson and Dolores A. Hutcheson v. Commissioner.

United States Tax Court.

Filed March 14, 1996.

Attorney(s) appearing for the Case

Robert E. Bergin, Fresno, Calif., for the petitioners. Ewan D. Purkiss, for the respondent.

MEMORANDUM OPINION

RAUM, Judge:

The Commissioner determined a deficiency in petitioners' 1989 income tax in the amount of $809,180. The issues for decision are: (1) Whether petitioners must recognize the entire gain from the sale of 100,000 shares of WalMart stock in January 1989 even though they "repurchased" 96,600 shares of WalMart in December 1989, and alternatively (2) whether the sale and "repurchase" of the stock qualifies as an involuntary conversion...

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