BENSON v. COMMISSIONER

Docket No. 5885-76.

37 T.C.M. 989 (1978)

T.C. Memo. 1978-231

John T. Benson, Jr., and Jimmie L. Benson v. Commissioner.

United States Tax Court.

Filed June 21, 1978.


Attorney(s) appearing for the Case

William Waller, One Commerce Place, Nashville, Tenn., for the petitioners. W. Robert Pope, Jr., for the respondent.


Memorandum Findings of Fact and Opinion

HALL, Judge:

Respondent determined deficiencies in petitioners' 1972 and 1973 Federal income taxes of $14,141.60 and $590.28,1 respectively. The sole issue for decision is whether petitioners realized gain on the transfer of stock to their sons where the transfer was conditioned upon the sons' promise to pay the resulting federal and state gift...

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