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FORSHEW v. COMMISSIONER

Docket No. 110687.

2 T.C.M. 337 (1943)

Charlotte J. Forshew v. Commissioner.

United States Tax Court.

Entered June 28, 1943.

Attorney(s) appearing for the Case

M. L. Seidman, C. P. A., 80 Broad St., New York City, for the petitioner. E. E. Strickland, Esq., for the respondent.

Memorandum Findings of Fact and Opinion

LEECH, Judge:

Respondent has determined a deficiency in income tax of petitioner in the sum of $927 for the calendar year 1939. The issue is whether the gain of $17,950.23 realized by petitioner upon receipt from a corporation of a payment in redemption of stock therein owned by her, is taxable in full or only to the extent of 50 per cent as a long-term gain under section 115 (c) of the Internal Revenue Code.

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