BOYLE v. COMMISSIONER OF INTERNAL REVENUE

No. 10314.

187 F.2d 557 (1951)

BOYLE v. COMMISSIONER OF INTERNAL REVENUE.

United States Court of Appeals Third Circuit.

Decided February 27, 1951.


Attorney(s) appearing for the Case

Llewellyn A. Luce, Washington, D. C., for petitioner.

Irving I. Axelrad, Washington, D. C. (Theron Lamar Caudle, Asst. Atty. Gen., Ellis N. Slack, A. F. Prescott, Sp. Assts. to Atty. Gen., on the brief), for respondent.

Before MARIS, McLAUGHLIN and HASTIE, Circuit Judges.


McLAUGHLIN, Circuit Judge.

This is a petition to review a decision of the Tax Court holding that payment by a corporation to the taxpayer for a portion of his shares of stock in that concern was, under the facts of the case, essentially equivalent to the distribution of a taxable dividend in accordance with Section 115(g) of the Internal Revenue Code.1

Petitioner, an engineer, is the inventor of a number of inflatable rubber articles...

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