United States Tax Court September 28, 1982, Docket No. 3734-80 (New York Fruit Auction Corp. v. Commissioner)

lead-opinion

Tannenwald, Chief Judge:

Respondent determined deficiencies in petitioner’s Federal income tax in the amounts of $27,007, $24,480, and $23,945 for the taxable years 1974,1975, and 1976, respectively. The sole issue for our determination is whether petitioner is entitled to a stepped-up basis in its assets, equal to the price paid for petitioner’s stock by Cayuga Corp.