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KUCHMAN v. COMMISSIONER

Docket No. 29434.

18 T.C. 154 (1952)

HAROLD H. KUCHMAN AND JENNIE F. KUCHMAN, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 30, 1952.

Attorney(s) appearing for the Case

Harry J. Rudick, Esq., Mason G. Kassel, Esq., and Joyce Stanley, Esq., for the petitioners.

Scott A. Dahlquist, Esq., for the respondent.

Respondent determined a deficiency in income tax of $5,300.49 against petitioners for the year 1945. The question is whether respondent erred in determining that the differential, if any, between the price paid and the fair market value of stock purchased by petitioner Harold H. Kuchman in 1945 was income to him. Some of the facts were stipulated.

[18 T.C. 155]

FINDINGS OF FACT.

The facts as stipulated are hereby found.

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