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JANEWAY v. COMMISSIONER OF INTERNAL REVENUE

Nos. 29, 30.

147 F.2d 602 (1945)

JANEWAY et ux. v. COMMISSIONER OF INTERNAL REVENUE. SHIELDS v. SAME.

Circuit Court of Appeals, Second Circuit.

February 6, 1945.

Attorney(s) appearing for the Case

Wright, Gordon, Zachry, Parlin & Cahill, of New York City (Charles C. Parlin and Robert C. Brown, both of New York City, of counsel), for petitioners.

Samuel O. Clark, Jr., Asst. Atty. Gen., and Sewall Key, A. F. Prescott, and Newton K. Fox, all of Washington, D. C., for respondent.

Before CHASE, HUTCHESON, and FRANK, Circuit Judges.

FRANK, Circuit Judge.

We read the findings of the Tax Court taken together with its opinion1 as saying that, as a matter of fact, all the payments made by the taxpayers to the corporation were capital contributions of such character that, as against any third persons (such as, e.g., persons contracting with the corporation) the taxpayers would have to be regarded as stockholders and nothing else. As the Tax Court's conclusion rests upon...

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