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UNITED NATIONAL CORPORATION v. COMMISSIONER

Docket No. 110389.

2 T.C. 111 (1943)

UNITED NATIONAL CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 15, 1943.

Attorney(s) appearing for the Case

Roger L. Shidler, Esq., for the petitioner.

B. H. Neblett, Esq., and C. R. Maxwell, Esq., for the respondent.

The Commissioner determined a deficiency in income tax for the fiscal year ended June 30, 1939, in the sum of $3,224.86.

Petitioner contends that there is no deficiency and that it has overpaid tax in the sum of $1,170.27.

The principal issue is whether certain payments received in 1938 from a corporation in which petitioner was the sole stockholder for shares of its stock were essentially equivalent to the distribution...

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