Richard L. and Kelly D. Robson, (2000)
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Richard L. and Kelly D. Robson, (2000)
T.C. Memo. 2000-201
UNITED STATES TAX COURT RICHARD L. AND KELLY D. ROBSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15716-97. Filed June 29, 2000.William D. Sutter, Jr., for petitioners. Henry N. Carriger, for 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 so found. The stipulation of facts is incorporated herein by this reference. Petitioners resided in York, Nebraska, when they filed their petition in this case. References to petitioner are to Richard L. Robson.Petitioner has worked in the insurance industry since his graduation from college in 1963 with a degree in education. On or about March 4, 1980, petitioner and James Klute (Klute) decided to purchase all of the stock of Mid-Nebraska Insurors, Inc. (Mid-Nebraska), a local insurance agency. To effect that purchase, Mid-Nebraska borrowed $33,175 from York State Bank and Trust Co. (York). Mid-Nebraska then lent the proceeds to petitioner and Klute, and they ...See the full content of this document
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