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LOEWEN v. COMMISSIONER

Docket No. 13420-78.

76 T.C. 90 (1981)

GEORGE LOEWEN AND SELMA LOEWEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed January 19, 1981.

Attorney(s) appearing for the Case

Kyler Knobbe, for the petitioners.

Marvin T. Scott, for the respondent.

OPINION

SIMPSON, Judge:

The Commissioner determined a deficiency of $24,138.60 in the petitioners' Federal income tax for 1976. After a concession by the petitioners, the only issue to be decided is whether the investment credits which the petitioners received in prior years were subject to recapture in 1976 under section 47 of the Internal Revenue Code of 19541 when they transferred their farming business to a corporation...

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