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HARRIMAN v. COMMISSIONER

Docket No. 5779.

7 T.C. 1384 (1946)

E. ROLAND HARRIMAN, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated December 23, 1946.

Attorney(s) appearing for the Case

Frank E. Barnett, Esq., and Charles H. McAuliffe, Esq., for the petitioner.

Scott A. Dahlquist, Esq., for the respondent.

The respondent determined a deficiency of $30,835.36 in the petitioner's income tax liability for the year 1940.

The sole issue is whether certain distributions made to the petitioner in 1940 by the Harriman Thirty Corporation were distributions in complete liquidation or distributions in partial liquidation of that corporation.

FINDINGS OF FACT.

Certain facts were stipulated. The portions thereof material to the issue are as follows:

The...

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