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SULLIVAN v. COMMISSIONER

Docket Nos. 23026, 23027, 23028, 23029.

17 T.C. 1420 (1952)

JOHN L. SULLIVAN, ET AL., PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated February 29, 1952.

Attorney(s) appearing for the Case

Dorothy Ann Kinney, Esq., for the petitioners.

D. Louis Bergeron, Esq., and L. R. Van Burgh, Esq., for the respondent.

The Commissioner determined the following deficiencies in income taxes for 1943:

John L. Sullivan --------------   $146,110.73
Georgia E. Sullivan -----------    146,110.73
B. C. Garnett -----------------    126,621.79
Betty K. S. Garnett -----------    162,463.79

The issue which is common to all four proceedings is whether a distribution in kind, made on April 1, 1943, by Texon Royalty Company (Delaware) to two stockholders in cancelation of two...

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