Walter Crocker and Norma Crocker, Petitioners-Appellants-Cross-Appellees v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-Appellant

Sixth Circuit

Walter Crocker and Norma Crocker, Petitioners-Appellants-Cross-Appellees v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-Appellant

571 F.2d 338

CourtCourt of Appeals for the Sixth Circuit

DecidedFebruary 17, 1978

Docket76-1432

StatusPublished

This text of 571 F.2d 338 (Walter Crocker and Norma Crocker, Petitioners-Appellants-Cross-Appellees v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-Appellant) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Walter Crocker and Norma Crocker, Petitioners-Appellants-Cross-Appellees v. Commissioner of Internal Revenue, Respondent-Appellee-Cross-Appellant, 571 F.2d 338 (6th Cir. 1978).

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Opinion

571 F.2d 338

78-1 USTC P 9283

Walter CROCKER and Norma Crocker,
Petitioners-Appellants-Cross-Appellees,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee-Cross-Appellant.

Nos. 76-1432, 76-1784.

United States Court of Appeals,
Sixth Circuit.

Feb. 17, 1978.

James D. O'Connell, Highland Park, Mich., for petitioners-appellants.

Jonathan S. Cohen, Robert T. Duffy, Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews, Tax Div., U. S. Dept. of Justice, Washington, D. C., Meade Whitaker, Chief Counsel, I. R. S., Washington, D. C., for respondent-appellee.

ORDER

Before EDWARDS, CELEBREZZE and PECK, Circuit Judges.

This is an appeal from a decision of the Tax Court finding a deficiency in income tax due for the year 1972. The case was submitted on the briefs and oral arguments of counsel, and the Court has studied the record and is fully advised in the premises.

The issues are whether taxpayers are entitled to nonrecognition of gains realized on the sale of one or both of two residences sold in 1972, and, if only one gain is recognized, which gain should be so treated. Internal Revenue Code § 1034. Taxpayers contend that they are entitled to nonrecognition of the gains realized on the sale of both residences.

We determine that the findings of the United States Tax Court are not clearly erroneous.

It is therefore ordered that the decision of the United States Tax Court be and hereby is affirmed.

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571 F.2d 338

78-1 USTC P 9283

Walter CROCKER and Norma Crocker,
Petitioners-Appellants-Cross-Appellees,
v.
COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee-Cross-Appellant.

Nos. 76-1432, 76-1784.

United States Court of Appeals,
Sixth Circuit.

Feb. 17, 1978.

James D. O'Connell, Highland Park, Mich., for petitioners-appellants.

Jonathan S. Cohen, Robert T. Duffy, Scott P. Crampton, Asst. Atty. Gen., Gilbert E. Andrews, Tax Div., U. S. Dept. of Justice, Washington, D. C., Meade Whitaker, Chief Counsel, I. R. S., Washington, D. C., for respondent-appellee.

ORDER

Before EDWARDS, CELEBREZZE and PECK, Circuit Judges.

This is an appeal from a decision of the Tax Court finding a deficiency in income tax due for the year 1972. The case was submitted on the briefs and oral arguments of counsel, and the Court has studied the record and is fully advised in the premises.

The issues are whether taxpayers are entitled to nonrecognition of gains realized on the sale of one or both of two residences sold in 1972, and, if only one gain is recognized, which gain should be so treated. Internal Revenue Code § 1034. Taxpayers contend that they are entitled to nonrecognition of the gains realized on the sale of both residences.

We determine that the findings of the United States Tax Court are not clearly erroneous.

It is therefore ordered that the decision of the United States Tax Court be and hereby is affirmed.

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571 F.2d 338, Counsel Stack Legal Research, https://law.counselstack.com/opinion/walter-crocker-and-norma-crocker-petitioners-appellants-cross-appellees-v-ca6-1978.