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WILLIAMS v. COMMISSIONER

Docket No. 27732.

12 T.C.M. 186 (1953)

Thomas L. Williams v. Commissioner.

United States Tax Court.

Entered February 24, 1953.

Attorney(s) appearing for the Case

Daniel A. Taylor, Esq., Joseph B. Crowley, Esq., and John F. Kelly, Jr., Esq., for the petitioner. Harold H. Hart, Esq., and Paul Levin, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

JOHNSON, Judge:

Respondent determined a deficiency in income tax for the year 1944 in the amount of $183,397.06. The issues before us are as follows:

(1) In a corporate reorganization, was the receipt of stock by petitioner a taxable dividend?

(2) In the alternative, if the transaction was not tax free, is the gain taxable as a long-term capital gain?

(3) Again, in the alternative, if the transaction...

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