United States Tax Court August 30, 1976, Docket No. 2084-73 (Deyoe v. Commissioner)

lead-opinion

Hall, Judge:

Respondent determined the following deficiencies in petitioner’s Federal income tax:

Year Deficiency

1969_ $21,222.25

1970_ 26,118.93

Because of concessions made by the parties, the sole issue before the Court is whether section 1239 of the Internal Revenue Code of 19541 applies to petitioner’s sale of her community interest in a ranch to George W.