DOYLE v. DISTRICT OF COLUMBIA

No. 19874.

363 F.2d 694 (1966)

Burton W. DOYLE, Petitioner, v. DISTRICT OF COLUMBIA, Respondent.

United States Court of Appeals District of Columbia Circuit.

Decided June 30, 1966.


Attorney(s) appearing for the Case

Mr. Julius I. Fox, Washington, D. C., with whom Mr. C. Richard Beyda, Washington, D. C., was on the brief, for petitioner.

Mr. Henry E. Wixon, Asst. Corp. Counsel for District of Columbia, with whom Messrs. Milton D. Korman, Acting Corp. Counsel, and Ronald L. Lenkin, Asst. Corp. Counsel, were on the brief, for respondent.

Before PRETTYMAN, Senior Circuit Judge, and DANAHER and McGOWAN, Circuit Judges.


DANAHER, Circuit Judge:

The taxpayer in 1963 was the majority stockholder in Doyle Printing & Offset Company, Inc., hereinafter the Corporation. On December 29, 1963, he transferred to that Corporation 3,170 of its shares for which he then received $40,000 in cash and a promissory note for $181,900.1 The District of Columbia tax authorities assessed a deficiency in income tax of $9,260 plus interest which the taxpayer paid under protest...

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