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KIND v. COMMISSIONER

Docket No. 6386-67.

54 T.C. 600 (1970)

WILLIAM C. KIND AND HELENE KIND, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 25, 1970.

Attorney(s) appearing for the Case

Allan Bakst, for the petitioners.

James Q. Smith, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in petitioners' income tax for 1962 in the amount of $4,771.86. The sole issue presented for decision is whether certain assets were received by petitioners in 1962 as a distribution in complete liquidation of a corporation, taxable as capital gain, or as a dividend, taxable as ordinary income.

FINDINGS OF FACT

Petitioners William C. and Helene Kind, husband and wife, were legal residents...

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