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LAMBLE v. COMMISSIONER

Docket No. 827-66.

26 T.C.M. 912 (1967)

T.C. Memo. 1967-185

William E. Lamble and Florence G. Lamble v. Commissioner.

United States Tax Court.

Filed September 22, 1967.

Attorney(s) appearing for the Case

Jacques T. Schlenger, 1400 Mercantile Trust Bldg., Baltimore, Md., and Theodore W. Hirsh, for the petitioners. Charles F. T. Carroll, for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency in income tax of petitioners in the amount of $3,351.26 for the year 1962. The sole issue is whether the sale by William E. Lamble in 1962 of a business individually owned by him to a corporation in which he owned all of the common (but none of the preferred) stock resulted in the receipt by him of a dividend distribution from that corporation.

Findings of Fact

Some...

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