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HAY v. COMMISSIONER

Docket No. 106801.

2 T.C. 460 (1943)

WILLIAM C. HAY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated July 23, 1943.

Attorney(s) appearing for the Case

Joseph D. Brady, Esq., and A. J. Hair, Esq., for the petitioner.

B. H. Neblett, Esq., Samuel Taylor, Esq., and Alva C. Baird, Esq., for the respondent.

Petitioner contests the determination of a deficiency in his income tax liability for the calendar year 1937 in the amount of $484,093.20. The controversy centers in an adjustment made by the Commissioner, in explanation of which the following is the only statement appearing in the notice of deficiency:

(b) Gain on disposition of capital stock of William C. Hay, Limited, is determined in the amount of $2,459,083.00. Inasmuch as the assets had been held for over 10...

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