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SORIN v. COMMISSIONER

Docket No. 89661.

23 T.C.M. 524 (1964)

T.C. Memo. 1964-87

Murray Sorin and Patricia Sorin (Husband and Wife) v. Commissioner.

United States Tax Court.

Filed March 31, 1964.

Attorney(s) appearing for the Case

Samuel Becker, for the petitioners. Joseph M. Touhill, for the respondent.

Memorandum Findings of Fact and Opinion

MULRONEY, Judge:

The respondent determined deficiencies in the petitioners' income tax for 1950 in the amount of $17,283.90. The issue is whether the amount of $50,000 received by petitioner Patricia Sorin is taxable as ordinary income as a distribution from a collapsible corporation under section 117(m) of the Internal Revenue Code of 1939.1

Findings of Fact

Some of the...

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