SEXTON v. COMMISSIONER

Docket No. 4428-78.

42 T.C.M. 1030 (1981)

T.C. Memo. 1981-494

Joe Alvin Sexton and Novena J. Sexton v. Commissioner.

United States Tax Court.

Filed September 10, 1981.


Attorney(s) appearing for the Case

Gregory W. Walkauskas, for the petitioners. Charles W. Kite, for the respondent.


Memorandum Opinion

FEATHERSTON, Judge:

Respondent determined a deficiency of $4,423.58 in petitioners' Federal income tax for 1974. The sole issue for decision is whether petitioners must recapture investment credit, taken as shareholders of a subchapter S corporation, upon the liquidation of the subchapter S corporation and the transfer of the business to a partnership.

All of the facts have been stipulated.

Petitioners Joe Alvin Sexton...

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