Jason L. Honigman and Edith Honigman, Petitioners-Cross-Appellees v. Commissioner of Internal Revenue, Respondent-Cross-Appellant

PHILLIPS, Chief Judge.

This is an appeal and cross-appeal from a decision of the United States Tax Court reported at 55 T.C. 1067 (1971). We affirm as to the issues on appeal and reverse as to the issue on cross-appeal.

The principal controversy involves the tax consequences of the sale of corporate property below market value to a minority shareholder. A secondary unrelated question will be treated in Part III of this opinion, infra.

I

Reference is made to the reported Tax Court decision for a detailed statement of the facts. The National Building Corporation was incorporated under the laws of…