COMMISSIONER OF INTERNAL REV. v. HIRSHON TRUST

No. 207, Docket No. 22940.

213 F.2d 523 (1954)

COMMISSIONER OF INTERNAL REVENUE v. HIRSHON TRUST et al.

United States Court of Appeals Second Circuit.

Decided May 17, 1954.


Attorney(s) appearing for the Case

Melva M. Graney, Washington, D. C. (H. Brian Holland, Asst. Atty. Gen., Ellis N. Slack and Lee A. Jackson, Sp. Assts. to the Atty. Gen., of counsel), for petitioner.

John P. Allison, New York City (Silverson & Allison, New York City, of counsel), for respondent.

Before CLARK, HINCKS and HARLAN, Circuit Judges.


HARLAN, Circuit Judge.

The question raised by this petition is the extent to which the fair market value of a corporate distribution in kind is taxable to the shareholder-distributees as ordinary dividend income where the earnings and profits of the distributing corporation are sufficient to cover the adjusted cost of the property distributed but are insufficient to cover its full fair market value at the time of the distribution.

In 1947, Southern Natural...

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