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HAMRICK v. COMMISSIONER

Docket No. 2479-62.

43 T.C. 21 (1964)

JAMES C. HAMRICK AND L. G. HAMRICK, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 20, 1964.

Attorney(s) appearing for the Case

Arthur M. Jenkins, for the petitioners.

John L. Ridenour III, for the respondent.

BRUCE, Judge:

The respondent determined deficiencies in income tax for the calendar years 1958, 1959, and 1960 in the amounts of $653.76, $7,257.32, and $90,518.08, respectively.

The principal issue for decision is whether certain shares of stock in a corporation received by James C. Hamrick in the taxable years constituted nontaxable income within the provisions of section 351 of the Internal Revenue Code of...

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