BLUM v. COMMISSIONER

Docket No. 5791.

5 T.C. 303 (1945)

GLADYS C. BLUM, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 21, 1945.


Attorney(s) appearing for the Case

Maurice Epstein, Esq., for the petitioner.

D. Louis Bergeron, Esq., for the respondent.


The respondent determined deficiencies in income tax for the years 1939, 1940, and 1941 in the respective amounts of $542.19, $1,034.26, and $1,674.76. The only question at issue is whether the gains realized by petitioner from the disposition of shares of corporate stock is taxable under section 115 (c) of the Internal Revenue Code as distributions in partial liquidation or under section 117 as gains from the sale of capital assets.

Petitioner filed her returns for...

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