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THORNLEY v. COMMISSIONER

Docket No. 385-62.

41 T.C. 145 (1963)

CHARLES J. AND FLORENCE THORNLEY, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 30, 1963.

Attorney(s) appearing for the Case

James R. McGowan, for the petitioners.

Joseph W. Salus II, for the respondent.

OPINION

FAY, Judge:

The respondent determined a deficiency in the petitioners' income tax in the amount of $5,168.15 for the taxable year 1958. The only issue for decision is whether the Thornley Supply Co. made a taxable distribution, consisting of eight insurance policies on the life of Charles J. Thornley, to its shareholder, Charles J. Thornley, in 1958.

All of the facts have been stipulated and are so found.

Charles J. Thornley...

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