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ROBSON v. COMMISSIONER

Docket No. 15716-97.

79 T.C.M. 2225 (2000)

T.C. Memo. 2000-201

Richard L. and Kelly D. Robson v. Commissioner.

United States Tax Court.

Filed June 29, 2000.

Attorney(s) appearing for the Case

William D. Sutter, Jr., for the petitioners. Henry N. Carriger, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

MARVEL, Judge:

Respondent determined a deficiency of $14,782 in petitioners' Federal income tax for the taxable year 1993. The sole issue for decision1 is whether petitioners realized a capital gain during 1993 as a result of a liquidating distribution under section 331(a)(1).2

FINDINGS OF FACT

Some of the facts have been stipulated and are...

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