United States Tax Court February 2, 1983, Docket No. 4788-79 (Estate of Applestein v. Commissioner)

lead-opinion

Wilbur, Judge:

Respondent determined a deficiency in petitioners’ Federal income tax for 1973 in the amount of $19,531.48.1 The issues presented for our determination are (1) whether petitioners are taxable on the gain reported by their two children from the exchange of National Realty stock transferred to them by petitioner Louis Applestein after the approval of a merger of National