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ESTATE OF STOUFFER v. COMMISSIONER

Docket No. 63606.

30 T.C. 1244 (1958)

ESTATE OF GORDON A. STOUFFER, DECEASED, MARK A. LOOFBOURROW, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 19, 1958.

Attorney(s) appearing for the Case

Warren E. Hacker, Esq., and Mark A. Loofbourrow, Esq., for the petitioner.

William O. Allen, Esq., for the respondent.

MULRONEY, Judge:

The respondent determined a deficiency in the income tax of petitioner's decedent for the year 1951 in the amount of $90,077.75, and in an amended answer alleged that the petitioner was liable for an additional deficiency of $233,418.48. The issues are (1) whether Gordon A. Stouffer, deceased, realized a gain when, in a divorce settlement with his wife, he surrendered an option that purportedly gave him the right to purchase certain shares...

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