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AMERICAN NURSERYMAN PUBLISHING CO. v. COMMISSIONER

Docket No. 6150-78.

75 T.C. 271 (1980)

AMERICAN NURSERYMAN PUBLISHING CO., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed November 17, 1980.

Attorney(s) appearing for the Case

Loren E. Juhl, Thomas E. Swaney, and Robert A. Malstrom, for the petitioner.

Allan E. Lang, for the respondent.

OPINION

SIMPSON, Judge:

The Commissioner determined a deficiency of $22,664.55 in the petitioner's Federal income tax for 1975. The only issue to be decided is whether an election by the petitioner to be treated as a small business corporation under subchapter S of the Internal Revenue Code of 19541 was terminated when a shareholder transferred her stock to a revocable trust of...

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