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ROBERTS v. COMMISSIONER

Docket No. 24285.

17 T.C. 1415 (1952)

JOHN T. ROBERTS AND FLORENCE V. ROBERTS, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 29, 1952.

Attorney(s) appearing for the Case

Stanley Worth, Esq., and Edward S. Smith, Esq., for the petitioners.

Stephen P. Cadden, Esq., for the respondent.

Petitioners attack respondent's determination of a deficiency in income tax of $77,068.90 for 1944. Two adjustments are not now contested. The issue remaining in controversy is whether a redemption of corporate stock constituted a distribution essentially equivalent to a dividend under section 115 (g), Internal Revenue Code. Some of the facts have been stipulated.

FINDINGS OF FACT.

The stipulated facts are hereby...

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