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CHRISTENSEN v. COMMISSIONER

Docket No. 71719.

33 T.C. 500 (1959)

FRITHIOF T. CHRISTENSEN AND RISE N. CHRISTENSEN, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 11, 1959.

Attorney(s) appearing for the Case

Alex Leslie Janes, Jr., Esq., for the petitioners.

James Booher, Esq., for the respondent.

OPINION.

FISHER, Judge:

Respondent determined a deficiency in income tax against petitioners for the taxable year 1953 in the amount of $1,324.09.

The sole issue presented for determination herein is whether petitioners received a taxable dividend when a corporation canceled the indebtedness of a former shareholder and assigned the proceeds of a life insurance policy to a former shareholder.

All of the facts are stipulated and, together...

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