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SALYER GRAIN AND MILLING COMPANY v. COMMISSIONER

Docket No. 21449-80.

51 T.C.M. 919 (1986)

T.C. Memo. 1986-165

Salyer Grain and Milling Company v. Commissioner.

United States Tax Court.

Filed April 22, 1986.

Attorney(s) appearing for the Case

Gary S. Vandeweghe, for the petitioner. Catherine L. Wong and Alan Summers, for the respondent.

Memorandum Findings of Fact and Opinion

CLAPP, Judge:

Respondent determined a deficiency in petitioner's Federal income tax in the amount of $288,000 for taxable year 1974. After concessions, the issue for decision is whether $600,000 of a $1.4 million payment by petitioner to Fred Greer constitutes consideration for the cancellation of an employment contract or whether all of the $1.4 million payment is allocable to a sale of stock. Petitioner claimed ...

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