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COMMISSIONER OF INTERNAL REVENUE v. PHIPPS

No. 3542.

167 F.2d 117 (1948)

COMMISSIONER OF INTERNAL REVENUE v. PHIPPS.

Circuit Court of Appeals, Tenth Circuit.

March 10, 1948.

Attorney(s) appearing for the Case

Harry Marselli, of Washington, D. C., (Theron Lamar Caudle, Asst. Atty. Gen., Helen R. Carloss, Lee A. Jackson, and Helen Goodner, Sp. Assts. to Atty. Gen., on the brief), for petitioner.

W. Clayton Carpenter, of Denver, Colo., (Montgomery Dorsey, Wm. L. Branch and Hughes & Dorsey, all of Denver Colo., on the brief), for respondent.

Before PHILLIPS, BRATTON and HUXMAN, Circuit Judges.

BRATTON, Circuit Judge.

This proceeding is here on petition to review a decision of the Tax Court. Margaret R. Phipps, hereinafter referred to as the taxpayer, owned certain shares of preferred stock issued by Nevada-California Electric Corporation. On or about December 1, 1936, Nevada-California Electric Corporation, hereinafter referred to as the parent company, liquidated five wholly owned subsidiary corporations and took over their assets in complete cancellation...

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