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ESTATE OF ERNSTING v. COMMISSIONER

Docket No. 64012.

18 T.C.M. 377 (1959)

T.C. Memo. 1959-77

Estate of John S. Ernsting, Deceased, Lou B. Ernsting, Executrix and Lou B. Ernsting, Surviving Wife v. Commissioner.

United States Tax Court.

Filed April 23, 1959.

Attorney(s) appearing for the Case

Albert W. Strang, Esq., for the petitioners. Leo K. O'Brien, Esq., and Richard W. Janes, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

Respondent determined a deficiency in income tax in the amount of $9,017.54 for the year ended December 31, 1951.

The issues are:

1. Did John S. Ernsting receive a distribution in partial liquidation of The Ernsting Company in 1951 consisting of cash in the amount of $50,000 and inventory items valued at $7,881.77?

2. If so, what was the cost or other basis of the stock of The Ernsting Company held...

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