STANDARD REALIZATION COMPANY v. COMMISSIONER

Docket No. 12322.

10 T.C. 708 (1948)

STANDARD REALIZATION COMPANY, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated April 29, 1948.


Attorney(s) appearing for the Case

John W. Martin, Esq., for the petitioner.

Frank B. Schlosser, Esq., for the respondent.


The Commissioner determined a deficiency of $28,871.75 in income tax of the petitioner for the period May 24-July 31, 1943, and a deficiency of $35,253.34 for the fiscal year ended July 31, 1944, in part by recomputing gains on the sales of mills which were contributed to it as paid-in surplus by its shareholders. Undivided interests in these mills had been distributed as a liquidating dividend to the shareholders immediately prior to their transfer to petitioner by a corporation...

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