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SEIDE v. COMMISSIONER

Docket Nos. 26116-26124, 30080, 30081.

18 T.C. 502 (1952)

DAISY SEIDE ET AL., PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Promulgated June 11, 1952.

Attorney(s) appearing for the Case

I. Herman Sher, Esq., R. A. Bartlett, Esq., and Martin A. Roeder, Esq., for the petitioners.

Francis X. Gallagher, Esq., for the respondent.

The question for decision is whether a distribution of debentures made by the Jersey Publishing Company in August 1942, in cancelation and redemption of its preferred stock resulted in the receipt of taxable income by the distributees. The Commissioner's determination that the debentures represented income, taxable in full, was the basis for his assertion of the following deficiencies in income tax:

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