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MORGAN v. COMMISSIONER

Docket No. 63331.

33 T.C. 30 (1959)

WALTER L. AND HELEN MORGAN, PETITIONERS, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed October 13, 1959.

Attorney(s) appearing for the Case

Andrew B. Young, Esq., and David P. Brown, Jr., Esq., for the petitioners.

Edward L. Newberger, Esq., for the respondent.

Respondent determined a deficiency in petitioners' income tax for the year 1952 in the amount of $168,442.85. Respondent has conceded that one adjustment was erroneously made. The two issues now before us arise out of the determination by the respondent as to the nature of certain corporate distributions, explained in the statutory notice as follows:

(a) Distributions to you by the following corporations as purported liquidating...

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