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STERN v. COMMISSIONER

Docket No. 19703.

15 T.C. 521 (1950)

THEODORE D. STERN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated October 18, 1950.

Attorney(s) appearing for the Case

Daniel A. Taylor, Esq., and George D. Crowley, Esq., for the petitioner.

Charles D. Leist, Esq., for the respondent.

The Commissioner determined a deficiency of $67,327.66 in income tax of the petitioner for 1943. The issues for decision are (1) whether the gain from the liquidation of 670 shares of Clark Linen Co. stock was income of the petitioner for 1942 despite his efforts to give away the shares, and (2) whether income of a partnership, Clark Linen and Equipment Co., for the period November 7, 1942, through April 30, 1943, to the extent that...

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