ROBINETTE v. COMMISSIONER

Docket No. 1176.

3 T.C.M. 398 (1944)

Lenore S. Robinette v. Commissioner.

United States Tax Court.

Entered April 27, 1944.


Attorney(s) appearing for the Case

John J. Goldberg, Esq., 111 Sutter St., San Francisco, Calif., for the petitioner. H. R. Horrow, Esq., for the respondent.


Memorandum Findings of Fact and Opinion

This proceeding involves a deficiency in income taxes for the period February 1, 1939 to December 31, 1939 in the amount of $665.92. The sole question is whether a distribution by a corporation of which the petitioner was a stockholder was a distribution of earnings and profits of the corporation or was, in part, a distribution of capital.

Findings of Fact

The petitioner is an individual residing in the State...

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