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POPE v. COMMISSIONER

Docket No. 53344.

15 T.C.M. 181 (1956)

T.C. Memo. 1956-41

Roger W. Pope and Marjorie H. Pope v. Commissioner.

United States Tax Court.

Filed February 23, 1956.

Attorney(s) appearing for the Case

Edmund Burke, Esq., for the petitioners. Burton L. Williams, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

The Commissioner determined a deficiency of $14,782.14 in the petitioners' income tax for 1949. The only issue for decision is whether the proceeds of the sale of certain shares of stock owned by Roger W. Pope in a corporation controlled by him to another corporation also controlled by him are taxable as long-term capital gain to the extent they are in excess of his cost basis or as a dividend.

Findings of Fact

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