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GUINNESS v. UNITED STATES

No. 43726.

73 F.Supp. 119 (1947)

GUINNESS v. UNITED STATES.

Court of Claims.

July 7, 1947.

Attorney(s) appearing for the Case

Thomas E. Harris, of Washington, D. C. (Ellsworth C. Alvord, Floyd F. Toomey and William H. Quealy, all of Washington, D. C., on the brief), for plaintiff.

J. W. Hussey, of Washington, D. C., and Sewall Key, Acting Asst. Atty. Gen. (Helen R. Carloss and Andrew D. Sharpe, both of Washington, D. C., on the brief), for defendant.

Before MADDEN, JONES, WHITAKER and LITTLETON, Judges.

MADDEN, Judge.

The plaintiff was a partner in the investment banking firm of Ladenburg, Thalmann and Company. In 1930 165,000 shares of the stock of Standard Power and Light Corporation, which stock was owned, directly or indirectly by the partnership, was sold to the United States Electric Power Corporation at a large profit. The question here is the extent to which the plaintiff became liable for federal income tax upon his share of this profit.

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