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WILSON v. COMMISSIONER

Docket Nos. 841-63, 842-63.

42 T.C. 914 (1964)

MARNE S. WILSON AND MARJORIE WILSON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT LYLE C. WILSON AND PEGGY WILSON, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 19, 1964.

Attorney(s) appearing for the Case

Alfred E. Holland, for the petitioners.

Leo A. McLaughlin, for the respondent.

The Commissioner determined deficiencies in 1958 income tax in the amount of $11,838.30 against Marne S. and Marjorie M. Wilson, and in the amount of $11,710.28 against Lyle C. and Peggy Wilson.

At issue is whether petitioners' receipt of stock in Wil-Plan Co. in a so-called spin-off qualified for nonrecognition under section 355, I.R.C. 1954.

FINDINGS OF FACT

Petitioners Marne S. and Marjorie M. Wilson, husband and wife, and Lyle C. and Peggy Wilson...

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