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HARTLEY v. COMMISSIONER

Docket No. 4355-65.

26 T.C.M. 186 (1967)

T.C. Memo. 1967-38

Enola C. Hartley v. Commissioner.

United States Tax Court.

Filed February 28, 1967.

Attorney(s) appearing for the Case

M. R. Nachman, Jr., for the petitioner. Robert G. Faircloth, for the respondent.

Memorandum Findings of Fact and Opinion

MULRONEY, Judge:

Respondent determined a deficiency in petitioner's 1960 income tax in the amount of $77,254.04. The deficiency results from respondent's determination that when petitioner incorporated her sole proprietorship business in 1960 she transferred to the corporation all and not a specified portion of her sole proprietorship business assets and received back not only stock but other property in the form of...

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