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BATEMAN v. COMMISSIONER

Docket No. 93310.

40 T.C. 408 (1963)

WILLIAM H. BATEMAN AND ANNABELLE P. BATEMAN, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 27, 1963.

Attorney(s) appearing for the Case

Sydney C. Winton and Sherwin Kamin, for the petitioners.

Alvin C. Martin, for the respondent.

OPINION

SCOTT, Judge:

Respondent determined a deficiency in petitioners' income tax for the calendar year 1958 in the amount of $11,212.36.

The issues for decision are:

(1) Should gain to petitioners be recognized under the provisions of section 356(a) (1) of the Internal Revenue Code of 1954 to the extent of the fair market value of common stock purchase warrants of the Symington Wayne Corp. which were received by William H. Bateman...

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