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HOUSTON NATURAL GAS CORP. v. COMMISSIONER OF INT. REV.

No. 12274.

173 F.2d 461 (1949)

HOUSTON NATURAL GAS CORPORATION (TEXAS) v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Fifth Circuit.

March 19, 1949.

Attorney(s) appearing for the Case

T. E. Kennerly, of Houston, Tex., and Ellsworth C. Alvord, Floyd F. Toomey, C. Rudolph Peterson and John P. Lipscomb, Jr., all of Washington, D. C., for petitioner.

Theron L. Caudle, Asst. Atty. Gen., Chas. Oliphant, Chief Counsellor, Bureau of Int. Rev., and Claude R. Marshall, Sp. Atty., Bureau of Int. Rev., both of Washington, D. C., and Geo. A. Stinson and Melva M. Graney, Sp. Assts. to Atty Gen., for respondent.

Before HUTCHESON, HOLMES, and LEE, Circuit Judges.

HUTCHESON, Circuit Judge.

This petition for review of the decision and order of the Tax Court, holding petitioner liable as transferee of Houston Natural Gas Corporation of Delaware, hereafter called "Delaware", presents the single, and on its face simple, question of law, whether, upon the liquidation of its subsidiaries in 1940, Delaware realized taxable income of $310,918.80, the admitted difference between the purchase price of the bonds of its subsidiaries and...

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