WATERMAN STEAMSHIP CORPORATION v. COMMISSIONER

Docket No. 6500-66.

50 T.C. 650 (1968)

WATERMAN STEAMSHIP CORPORATION, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed July 31, 1968.


Attorney(s) appearing for the Case

William H. Armbrecht, Jr., Marshall J. DeMouy, and Louis H. Anders, Jr., for the petitioner.

Robert G. Faircloth, for the respondent.


SCOTT, Judge:

Respondent determined a deficiency in petitioner's income tax for the taxable period January 1, 1955, through May 5, 1955, in the amount of $196,744.93.

Some of the issues raised by the pleadings have been disposed of by agreement of the parties leaving for our decision whether the distribution of a promissory note by Pan-Atlantic Steamship Corp. in the principal sum of $2,799,820 to Waterman Steamship Corp. was a dividend or part of the...

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