MacDONALD v. COMMISSIONER OF INTERNAL REVENUE

No. 232.

76 F.2d 513 (1935)

MacDONALD v. COMMISSIONER OF INTERNAL REVENUE.

Circuit Court of Appeals, Second Circuit.

Decided April 1, 1935.


Attorney(s) appearing for the Case

Frederick Schwertner, of Washington, D. C., for petitioner.

Frank J. Wideman, Asst. Atty. Gen., and Sewall Key and John G. Remey, Sp. Assts. to Atty. Gen., for respondent.

Before MANTON, L. HAND, and CHASE, Circuit Judges.


MANTON, Circuit Judge.

This petition seeks a review of income taxes assessed for the years 1928 and 1929. Appellant, owner of all the common stock, 1,500 shares, of the Lockwood Trade Journal Company, Inc., contracted to purchase 1,425 shares of the preferred stock of that company, on July 10, 1928. He paid therefor $62,700 in cash, and executed and delivered Series A notes for a total sum of $128,250; a Series B note for $80,000; and Series C notes for $51,300, as...

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