HOLMES v. COMMISSIONER

Docket No. 9839-76.

37 T.C.M. 1825 (1978)

T.C. Memo. 1978-437

Tom H. Holmes, Jr. and Pat A. Holmes v. Commissioner.

United States Tax Court.

Filed November 2, 1978.


Attorney(s) appearing for the Case

Richard Lee Brown, 2600 Ft. Worth Natl. Bank Bldg., Ft. Worth, Tex., for the petitioners. John F. Dean, for the respondent.


Memorandum Findings of Fact and Opinion

GOFFE. Judge:

The Commissioner determined a deficiency in petitioners' Federal income tax in the amount of $9,514.53 for the taxable year 1972.

The sole issue for our decision is whether $52,500 received by petitioners under an agreement restricting the sale of Granbury State Bank stock should be taxable as ordinary income in the year of receipt.

Findings of Fact

Some of the facts have been...

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