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ELLIOTT v. COMMISSIONER

Docket No. 67550.

32 T.C. 283 (1959)

ISABEL A. ELLIOTT, INDIVIDUALLY, AND ESTATE OF RANDALL T. ELLIOTT, DECEASED, ISABEL A. ELLIOTT, CO-EXECUTRIX, AND RANDALL T. ELLIOTT, JR., CO-EXECUTOR, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 30, 1959.

Attorney(s) appearing for the Case

Willis T. Barber, Esq., for the petitioners.

William O. Allen, Esq., for the respondent.

DRENNEN, Judge:

Respondent determined a deficiency in the income tax of petitioners for the year 1954 in the amount of $19,947.93 and additions to tax under section 294(d), I.R.C. 1939,1 in the amount of $3,395.87.

The only issue for determination is whether the distribution of all the stock of Centrifix Management Corporation, a wholly owned subsidiary, hereinafter referred to as Management, by Centrifix Corporation, hereinafter...

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