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ELIZABETH SUSAN STRAKE TRUST v. COMMISSIONER

Docket Nos. 109725, 109726, 109727.

1 T.C. 1131 (1943)

ELIZABETH SUSAN (BETTY SUE) STRAKE TRUST, BY J. L. MCCONN AND CHARLES A. PERLITZ, JR., AS TRUSTEES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. GEORGANNA ALICE STRAKE TRUST, BY J. L. MCCONN AND CHARLES A. PERLITZ, JR., AS TRUSTEES, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. GEORGE WILLIAM STRAKE, JR., TRUST, BY J. L. MCCONN AND CHARLES A. PERLITZ, JR., AS TRUSTEES, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated May 18, 1943.

Attorney(s) appearing for the Case

Charles A. Perlitz, Jr., Esq., for the petitioners.

S. B. Anderson, Esq., for the respondent.

OPINION.

ARNOLD, Judge:

Each of these proceedings, consolidated for hearing and decision, involves an income tax deficiency for 1939 of $2,645.05. The question presented is whether $10,655 should be included in the income of each petitioner as a distribution of earnings and profits taxable as a dividend because they purchased stock from a corporation in which they were shareholders for $10,655 less than...

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