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CASHION INC. v. COMMISSIONER

Docket Nos. 8536-76, 8537-76.

37 T.C.M. 1847 (1978)

T.C. Memo. 1978-466

Cashion, Inc., formerly Cashion Oil Company, Inc. v. Commissioner. Paul L. Cashion and Mary E. Cashion v. Commissioner.

United States Tax Court.

Filed November 22, 1978.

Attorney(s) appearing for the Case

Eric Davis, D St., Prof. Bldg., North Wilkesboro, N.C., for the petitioners. Eric B. Jorgensen, for the respondent.

Memorandum Findings of Fact and Opinion

SIMPSON, Judge:

The Commissioner determined a deficiency in the individual petitioners' Federal income tax for 1973 of $4,868.95 and a deficiency in the corporate petitioner's Federal income tax for 1973 of $5,828.24. The only issue for decision is which of the petitioners owned an 82.2-acre tract of land when it was sold to a third party in 1973.

Findings of Fact

Some of the facts have been stipulated...

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