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KUCZMARSKI v. COMMISSIONER

Docket No. 2486-71.

32 T.C.M. 811 (1973)

T.C. Memo. 1973-168

Leo N. Kuczmarski and Rita A. Kuczmarski v. Commissioner.

United States Tax Court.

Filed July 31, 1973.

Attorney(s) appearing for the Case

Leo N. Kuczmarski, pro se, 54 Four Seasons W., Eggertsville, N.Y. George W. Connelly, Jr., for the respondent.

Memorandum Findings of Fact and Opinion

HALL, Judge:

Respondent determined a $1,859.03 deficiency in petitioners' 1967 Federal income tax.

The issue to be decided is whether a certain transaction between American Steamship Company ("American") and Oswego Steamship Corporation ("Oswego") was a sale of American stock by its shareholders to Oswego for Oswego's cash and notes, or whether it was a sale of assets by American to Oswego for cash and notes...

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