LOWNDES v. UNITED STATES

No. 11193.

384 F.2d 635 (1967)

W. Bladen LOWNDES and Anne W. Lowndes, Appellants, v. UNITED STATES of America, Appellee.

United States Court of Appeals Fourth Circuit.

Decided October 13, 1967.


Attorney(s) appearing for the Case

P. McEvoy Cromwell, Baltimore, Md. (John D. Wright, Baltimore, Md., on the brief), for appellants.

William Friedlander, Atty., Dept. of Justice, (Mitchell Rogovin, Asst. Atty. Gen., Lee A. Jackson and Gilbert E. Andrews, Attys., Dept. of Justice, and Thomas J. Kenney, U. S. Atty., and Ronald T. Osborn, Asst. U. S. Atty., on the brief), for appellee.

Before SOBELOFF, BOREMAN and BRYAN, Circuit Judges.


SOBELOFF, Circuit Judge:

The question presented by this appeal is whether the taxpayer realized ordinary income when she purchased all of the outstanding stock of each of four corporations or whether she received income, taxable either as long term capital gain or as ordinary income, at the time of liquidation, more than six months after the acquisition of the stock of each corporation. The stock purchases were made in Mrs...

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