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REED v. COMMISSIONER

Docket No. 3662-79.

45 T.C.M. 398 (1982)

T.C. Memo. 1982-734

John E. Reed and Elizabeth G. Reed v. Commissioner.

United States Tax Court.

Filed December 23, 1982.

Attorney(s) appearing for the Case

John C. Klotsche and John M. Peterson, Jr., 2800 Prudential Plaza, Chicago, Ill., for the petitioners. Anita N. Gottlieb, for the respondent.

Memorandum Findings of Fact and Opinion

WILBUR, Judge:

Respondent determined a deficiency of $71,412.68 in petitioners' 1973 Federal income tax. The sole issue for our determination is whether capital gain from the sale of petitioners' stock was realized and recognized in 1973 or 1974.

Findings of Fact

Some of the facts have been stipulated. The stipulation of facts and the attached exhibits are incorporated herein by this reference.

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