ESTATE OF SQUIER v. COMMISSIONER

Docket No. 75848.

35 T.C. 950 (1961)

ESTATE OF ARTHUR H. SQUIER, DECEASED, NATIONAL STATE BANK OF NEWARK, EXECUTOR, PETITIONER, v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed March 16, 1961.


Attorney(s) appearing for the Case

Benjamin Alpert, Esq., for the petitioner.

Chapman H. Belew, Jr., Esq., for the respondent.


Respondent determined a deficiency in petitioner's income tax for the calendar year 1955 in the amount of $23,590.89. The issue is whether and to what extent the acquisition by Squier, Schilling and Skiff, Inc., of 737 shares of its common stock in 1955 from the estate of Arthur H. Squier was a redemption essentially equivalent to a dividend within the meaning of section 302 of the Internal Revenue Code of 1954.

FINDINGS OF FACT.

The stipulation of facts...

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