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AUTO FINANCE CO. v. COMMISSIONER

Docket No. 52753.

24 T.C. 416 (1955)

AUTO FINANCE COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed June 17, 1955.

Attorney(s) appearing for the Case

O. R. McGuire, Jr., Esq., and Richard A. Mullens, Esq., for the petitioner.

Ralph V. Bradbury, Jr., Esq., for the respondent.

Respondent determined a deficiency in petitioner's income tax for the taxable year ended August 31, 1948, in the amount of $143,705.01. The issue involved is whether amounts received upon the redemption or transfer of preferred stock of two companies controlled by petitioner as part of a plan to dispose of its entire interest in each of those companies, are taxable as dividends or as parts of the proceeds of the sale of its interest in each company.

FINDINGS OF FACT...

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