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AKERS v. COMMISSIONER

Docket No. 5957.

6 T.C. 693 (1946)

FLOYD D. AKERS, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 10, 1946.

Attorney(s) appearing for the Case

Frederic N. Towers, Esq., and Norman B. Frost, Esq., for the petitioner.

Philip A. Bayer, Esq., for the respondent.

This proceeding involves a deficiency of $88,135.88 in income tax for 1941. The issues are whether the petitioner received "going-concern value" upon the liquidation of the corporation of which he was the sole stockholder, and whether all the net income of a partnership is taxable to petitioner.

FINDINGS OF FACT.

The Capitol Cadillac Co., hereinafter referred to as the corporation, was organized in 1934, under the...

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