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ABBOTT v. COMMISSIONER OF INTERNAL REVENUE

Nos. 12439, 12440.

258 F.2d 537 (1958)

J. D. ABBOTT and Kathryn Abbott, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent. Carl M. WOLFE and Mary E. Wolfe, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Third Circuit.

Decided July 31, 1958.

Attorney(s) appearing for the Case

Harry Friedman, Washington, D. C. (Jerome C. Bachrach, Pittsburgh, Pa., on the brief), for petitioners.

Thomas N. Chambers, Washington, D. C. (Charles K. Rice, Asst. Atty. Gen., Lee A. Jackson, Harry Baum, Attys., Dept. of Justice, Washington, D. C., on the brief), for respondent.

Before GOODRICH, McLAUGHLIN and STALEY, Circuit Judges.

STALEY, Circuit Judge.

Two issues are presented by these consolidated petitions to review decisions of the Tax Court. The primary issue is whether the gain realized by taxpayers on the liquidation of their corporation is capital gain, or ordinary income under the "collapsible corporation" provisions of Section 117(m) of the Internal Revenue Code of 1939, as amended, 26 U.S.C. § 117(m). A secondary issue poses the question of whether the penalty under Section...

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