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LIDDON v. COMMISSIONER

Docket Nos. 41495, 41497.

22 T.C. 1220 (1954)

WILLIAM M. LIDDON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT. MARIA PROTHRO LIDDON, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed September 21, 1954.

Attorney(s) appearing for the Case

John J. Hooker, Esq., and Albert B. Maloney, C. P. A., for the petitioners.

Homer F. Benson, Esq., for the respondent.

Respondent determined the following deficiencies in income tax for 1948:

Docket No.                Petitioner                                  Deficiency

41495 --------------   William M. Liddon --------------------------   $26,598.77
41497 --------------   Maria Prothro Liddon -----------------------    22,058.15

The issue is whether the gain resulting from the liquidation of a closely held corporation is taxable as ordinary...

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