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MORRISON v. COMMISSIONER

Docket No. 6895-70.

59 T.C. 248 (1972)

JACK F. MORRISON AND MARGARET V. MORRISON, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed November 15, 1972.

Attorney(s) appearing for the Case

Benjamin G. Cox and Victor E. Aldridge, Jr., for the petitioners.

Robert P. Ruwe, for the respondent.

FEATHERSTON, Judge:

Respondent determined a deficiency in petitioners' income tax for 1966 in the amount of $36,555.77. The issues presented for decision are as follows:

(1) Whether a right to acquire 75 shares of stock in a corporation surviving a merger, in addition to a pro rata distribution of other shares, was received by petitioner Jack F. Morrison as consideration for future services and a covenant not...

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