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KRONENBERG v. COMMISSIONER

Docket No. 8656-72.

64 T.C. 428 (1975)

MAX KRONENBERG, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 17, 1975.

Attorney(s) appearing for the Case

Leslie R. Barth and Robert H. Horowitz, for the petitioner.

Jon T. Flask, for the respondent.

SIMPSON, Judge:

The Commissioner determined a deficiency of $98,344.76 in the petitioner's Federal income tax for the year 1967. Some concessions have been made; the issues remaining for decision are: (1) Whether liquidating distributions received by the petitioner after he became a nonresident alien are taxable under section 877 of the Internal Revenue Code of 1954,1 relating to expatriation to avoid tax; (2) the fair market value...

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