United States Tax Court July 23, 1987, Docket No. 18745-81. (Francis v. Commissioner)

RAYMOND J. AND MARIA E. FRANCIS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Francis v. Commissioner Docket No. 18745-81. United States Tax Court T.C. Memo 1987-362; 1987 Tax Ct. Memo LEXIS 362; 53 T.C.M. (CCH) 1427; T.C.M. (RIA) 87362; July 23, 1987. *362 In 1974 petitioners formed a corporation that issued stock to them based on a written plan.