Carol M. Read, et al. - Page 1

                                   114 T.C. No. 2                                     

                               UNITED STATES TAX COURT                                

                       CAROL M. READ, ET AL.,1 Petitioners v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket Nos. 19001-97, 19322-97,    Filed February 4, 2000.             

                    W and H, who were married, owned all of the vot-                  
               ing, and virtually all of the nonvoting, stock of X                    
               corporation (X).  They divorced, and the final judgment                
               dissolving their marriage (divorce judgment) ordered                   
               (1) that W sell and convey to H, or at H's election to                 
               X or X's ESOP plan, all of her X stock, (2) that H, or                 
               at H's election X or X's ESOP plan, pay a stated amount                
               of cash to W simultaneously with the sale and convey-                  
               ance of such stock, and (3) that as additional consid-                 
               eration H, or at H's election X or X's ESOP plan,                      
               deliver to W a promissory note bearing 9-percent inter-                
               est for the balance of the purchase price of that                      
               stock.  Pursuant to the divorce judgment, H elected                    
               (1) that the sale and conveyance of all of W's X stock                 

               1Cases of the following petitioners are consolidated here-             
          with:  Mulberry Motor Parts, Inc., docket No. 19322-97, and                 
          William A. Read, docket No. 19328-97.                                       

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