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CARPENTER v. COMMISSIONER

Docket No. 1539-64.

27 T.C.M. 768 (1968)

T.C. Memo. 1968-157

C. Clinton Carpenter and Phyllis S. Carpenter v. Commissioner.

United States Tax Court.

Filed July 23, 1968.

Attorney(s) appearing for the Case

Richard B. Spindle, III, 18th Floor, Virginia Nat'l Bank Bldg., Norfolk, Va., for petitioners. E. M. Paturis, for respondent.

Memorandum Findings of Fact and Opinion

ATKINS, Judge:

The respondent determined an income tax deficiency of $39,687.41 against the petitioners for the taxable year 1957. The issue for decision is whether the respondent correctly determined that the petitioners derived taxable income as a result of the foreclosure sale of certain stock which they had pledged as collateral for a loan to another corporation owned by the petitioner C. Clinton Carpenter.

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