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WANAMAKER TRUST. v. COMMISSIONER

Docket No. 15065.

11 T.C. 365 (1948)

TRUSTEES COMMON STOCK JOHN WANAMAKER PHILADELPHIA UNDER WILL OF RODMAN WANAMAKER, DECEASED, C. STEVENSON NEWHALL, ROBERT H. MONTGOMERY, GEORGE P. ORR, RODMAN BARKER, J. LEONARD REPLOGLE AND JOHN RODMAN WANAMAKER, SURVIVING AND SUCCEEDING TRUSTEES, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated September 27, 1948.

Attorney(s) appearing for the Case

C. Walter Randall, Jr., Esq., for the petitioners.

William H. Best, Jr., Esq., for the respondent.

This proceeding was brought for a redetermination of deficiencies in income tax as follows:

1942 ---------------------------------------------   $38,449.16
1943 ---------------------------------------------    31,224.24
1944 ---------------------------------------------    44,923.43

The questions presented are whether cash receipts by petitioners resulting from transactions between wholly owned corporations constituted distributions taxable as dividends...

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