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BRYDEN v. COMMISSIONER

Docket Nos. 72400, 72401.

18 T.C.M. 810 (1959)

T.C. Memo. 1959-184

Stanton H. Bryden and Rosemary Bryden v. Commissioner. Clark B. Bristol v. Commissioner.

United States Tax Court.

Filed September 30, 1959.

Attorney(s) appearing for the Case

Burton L. Williams, Esq., 85 Devonshire St., Boston, Mass., for the petitioners. Raymond T. Mahon, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

OPPER, Judge:

In these consolidated proceedings respondent determined deficiencies for the year 1954 in Stanton H. Bryden's and Rosemary Bryden's income tax of $1,395.02 and in Clark B. Bristol's income tax of $2,360.10.

The sole issue to be decided is the value, if any, to be attributed to the goodwill of the Bristol Insurance Agency, Inc., for the purpose of valuing the distribution to stockholders upon its...

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