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JACKSON v. COMMISSIONER OF INTERNAL REVENUE

Nos. 9546, 9547.

172 F.2d 605 (1949)

JACKSON v. COMMISSIONER OF INTERNAL REVENUE. FARRELL v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Seventh Circuit.

Rehearing Denied March 16, 1949.

Attorney(s) appearing for the Case

Carroll J. Lord, Leland K. Neeves, and Jess Halsted, all of Chicago, Ill., for petitioner.

Theron L. Caudle, Asst. Atty. Gen., Hilbert P. Zarky, U. S. Department of Justice, of Washington, D. C., and Ellis N. Slack and Helen Goodner, Sp. Assts. to Atty. Gen., for respondent.

Before MAJOR, Chief Judge, and KERNER and MINTON, Circuit Judges.

KERNER, Circuit Judge.

Petitioners, principal stockholders in an Illinois corporation and the recipients in 1941 of a distribution by the corporation of a total of $250,000 which the Tax Court held was taxable dividends, seek by their petitions for review to reverse the decisions of the Tax Court.

The Tax Court made findings of fact which for the most part had been stipulated. Stated concisely these facts are that...

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