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ATLEE v. COMMISSIONER

Docket No. 4222-73.

67 T.C. 395 (1976)

HARRY B. ATLEE AND COLLEEN ATLEE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed December 8, 1976.

Attorney(s) appearing for the Case

James F. Davis and Keith T. Childers, for the petitioners.

Robert E. Glanville, for the respondent.

WILBUR, Judge:

Respondent has determined deficiencies in petitioners' Federal income taxes for the years 1969 and 1970 in the amounts of $1,371.45 and $31,107.51, respectively. The issues presented for decision are: (1) Whether petitioners effected a tax-free corporate division under section 355,1 and (2) the fair market value of the stock of Atlee Enterprises, Inc., on the date such stock...

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