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LEVIN v. C. I. R.

Nos. 67, 68, Dockets 31379, 31380.

385 F.2d 521 (1967)

Beatrice LEVIN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Court of Appeals Second Circuit.

Decided October 11, 1967.

Attorney(s) appearing for the Case

Newton D. Brenner, New Haven, Conn. (Allen H. Duffy, Stephen L. Saltzman, New Haven, Conn., of counsel), for petitioner.

Louis M. Kauder, Atty., Dept. of Justice (Richard C. Pugh, Acting Asst. Atty. Gen., Meyer Rothwacks, Gilbert E. Andrews, Attys., Dept. of Justice, of counsel), for respondent.

Before MOORE, SMITH and KAUFMAN, Circuit Judges.

IRVING R. KAUFMAN, Circuit Judge:

The perils of acting without competent tax advice1 are demonstrated anew, if further evidence be needed, by this petition to review a decision of the Tax Court, 47 T.C. 258 (1966), holding that distributions in 1960, 1961, 1962, and 1963 to the taxpayer in redemption of her stock in a family corporation were "essentially equivalent to a dividend" within the meaning of section...

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