FRY v. COMMISSIONER

Docket No. 758.

5 T.C. 1058 (1945)

W. N. FRY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated November 14, 1945.


Attorney(s) appearing for the Case

W. G. Boone, Esq., for the petitioner.

Bernard D. Hathcock, Esq., for the respondent.


The respondent determined a deficiency in petitioner's income tax liability for the taxable year ended December 31, 1939, in the amount of $107.46, which deficiency is the result of respondent's determination that:

(a) The transaction whereby you received 25 shares of the common stock of the National Bank of Commerce from the Bank of Commerce & Trust Company constitutes a distribution in partial liquidation, and the gain...

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