United States Tax Court
Filed: Dec. 16, 2013
LARRY E. AUSTIN AND BELINDA AUSTIN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT ESTATE OF ARTHUR E. KECHIJIAN, DECEASED, SUSAN P. KECHIJIAN AND SCOTT E. HOEHN, CO-EXECUTORS, AND SUSAN P. KECHIJIAN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT Docket Nos. 8966–10, 8967–10. Filed December 16, 2013. Ps exchanged property for ostensibly restricted stock of a newly formed S corporation (S). The governing agreements provided that Ps, upon termination of employment, would ..