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ESTATE OF LENNARD v. COMMISSIONER

Docket No. 2011-70.

61 T.C. 554 (1974)

ESTATE OF MILTON S. LENNARD, DECEASED, PAULINE LENNARD AND GERALD L. LENNARD, EXECUTORS, AND PAULINE LENNARD, INDIVIDUALLY, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 29, 1974.

Attorney(s) appearing for the Case

Abraham S. Guterman, for the petitioners.

Larry Kars, for the respondent.

GOFFE, Judge:

Respondent determined deficiencies in petitioners' Federal income taxes for the years 1965 and 1966 in the respective amounts of $67,059.55 and $69,292.53. The issues for decision are (1) whether the redemption of all of Milton S. Lennard's stock in Gerald Metals, Inc., constituted a complete termination of his interest in the corporation under sections 302(b) (3) and 302(c) (2)1 when he continued to render accounting...

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