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HILL v. COMMISSIONER OF INTERNAL REVENUE

No. 3459.

66 F.2d 45 (1933)

HILL v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Fourth Circuit.

June 15, 1933.

Attorney(s) appearing for the Case

Edmund B. Quiggle, of Washington, D. C. (William W. Sledge, of Durham, N. C., on the brief), for petitioner.

Helen R. Carloss, Sp. Asst. to Atty. Gen. (Sewall Key, Sp. Asst. to Atty. Gen., and W. R. Lansford, Sp. Atty., Bureau of Internal Revenue, and C. M. Charest, Gen. Counsel, Bureau of Internal Revenue, both of Washington, D. C., on the brief), for respondent.

Before PARKER and SOPER, Circuit Judges, and ERNEST F. COCHRAN, District Judge.

ERNEST F. COCHRAN, District Judge.

The petition to review the decision of the Board of Tax Appeals in this case raises the question whether the sum of $25,000, received by the taxpayer from Union Bleachery, a South Carolina corporation, in the year 1927, should be considered a dividend under section 201 (g) of the Revenue Act of 1926, 44 Stat. 10, 11 (26 USCA § 932 (g), or a distribution in partial liquidation of the corporation, under section 201 (c) of that...

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