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VINNELL v. COMMISSIONER

Docket No. 1497-66.

52 T.C. 934 (1969)

ALLAN S. VINNELL AND PAULINE VINNELL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 11, 1969.

Attorney(s) appearing for the Case

Max Thelen, Jr., and David M. Bridges, for the petitioners.

Charles W. Nyquist, for the respondent.

HOYT, Judge:

Respondent determined a deficiency in petitioners' individual income tax for 1961 in the amount of $71,903.38. The following two issues must be decided: (1) Whether payments received by petitioners from the sale of stock in one of their controlled corporations to another of their controlled corporations, treated here as a distribution in redemption of the stock of the acquiring corporation, were essentially equivalent to a dividend; and if so,...

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