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SPANGLER v. COMMISSIONER

Docket Nos. 24452, 24603.

18 T.C. 976 (1952)

CHESTER E. SPANGLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. LUCILLE SPANGLER, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 10, 1952.

Attorney(s) appearing for the Case

Herbert W. Clark, Esq., and Leon de Fremery, Esq., for the petitioners.

H. A. Melville, Esq., and Chas. H. Chase, Esq., for the respondent.

The respondent determined deficiencies of $1,530.73 as to each of the petitioners' income taxes for the year 1943. The only remaining question after the abandonment by petitioners of several issues raised in the pleadings is whether the receipt of stock by petitioners was a taxable dividend, a nontaxable exchange or a capital gain or loss transaction.

FINDINGS OF FACT.

The facts stipulated are so found.

The petitioners are husband and wife, residing...

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