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PENN-WARRINGTON HOSIERY MILLS, INC. v. COMMISSIONER

Docket No. 80608.

20 T.C.M. 1050 (1961)

T.C. Memo. 1961-211

Penn-Warrington Hosiery Mills, Inc. v. Commissioner.

United States Tax Court.

Filed July 17, 1961.

Attorney(s) appearing for the Case

Howard G. Kulp, Jr., Esq., 628 Cooper St., Camden, N. Y., for the petitioner. David E. Crabtree, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

MULRONEY, Judge:

The respondent determined a deficiency in the petitioner's income tax for 1953 in the amount of $10,511.58. The issues are:

(1) Whether the gain realized by petitioner in a transaction between petitioner and another corporation in 1955 should be recognized within the meaning of section 355 or section 361 of the Internal Revenue Code of 1954; and

(2) Whether the fair market value of...

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